Sectors
Healthcare.
Hospitals are in scope on capacity like any other premises, and there is no tier cap. What the Act does provide is the identity of the Responsible Person — which settles a question most large estates would otherwise have to resolve.
01 — Scope
No cap, so numbers decide.
Schedule 1 paragraph 10 makes use as a hospital, or for the provision of health care, a specified use. Unlike worship, schools, childcare and further education, healthcare carries no tier cap. Where it is reasonable to expect that from time to time 800 or more individuals may be present at the same time, the enhanced duty applies.
For an acute hospital the answer is not marginal. Counting staff on shift, outpatients, visitors, contractors and volunteers together, most district generals are well past 800 on an ordinary weekday. The question is rarely whether, and almost always where the boundary of the premises sits.
02 — Who carries it
The Act names it directly.
Where the relevant Schedule 1 use is use as a hospital, paragraph 10 fixes the Responsible Person rather than leaving it to who controls the site:
- NHS trust, NHS foundation trust or Health and Social Care trust — that trust.
- Health Board or Special Health Board — that Board.
- Any other case — the governing body of the hospital.
That is unusually helpful. In a large estate with PFI partners, facilities contractors, retail tenants and a car park operator, the question of who the Responsible Person is would otherwise consume weeks. Here it is answered in the statute, and answered at trust or board level rather than at the level of the individual site manager.
03 — The substantive difficulty
A building that cannot lock down.
Healthcare carries a genuine tension the other sectors do not. The standard responses — evacuate, invacuate, lock down — assume people who can move and a building that can close. A hospital has neither.
- Patients who cannot be evacuated. Theatres, ITU and neonatal units cannot empty on an alarm. Procedures must state what happens instead, rather than omit those areas.
- An entrance that cannot close. Emergency departments must remain reachable. Lockdown, in the ordinary sense, is not available at the front door.
- Mixed tenancy. Concourse retail, a pharmacy, a coffee franchise and a car park may each have their own operator, staff and procedures.
- Round-the-clock occupancy. The 03:00 staffing picture is a different premises from the 11:00 one, and procedures written against the daytime picture assume people who are not present.
None of that is a reason to do less. It is the reason the documentation must be specific, and the reason a generic template does more harm in healthcare than almost anywhere else.
04 — Engagement
What an engagement produces here.
Healthcare engagements begin with the estate boundary and end with documentation specific enough to be followed at three in the morning.
- The premises boundary across tenancies, contractors and car parks.
- Procedures stating what happens in the areas that cannot evacuate.
- A documented vulnerability assessment and a named accountable individual, as the enhanced duty requires.
- An implementation plan carrying owners and dates, and an evidence pack a board can read.
Scoped to the premises, never to a package, and stated as a fixed fee before work begins — see how an engagement runs.
Next
Begin with the estate boundary.
Most healthcare engagements begin by establishing what constitutes the premises. Everything else follows from it.