In healthcare environments, ventilation is far more than a background utility, it is a clinical safeguard. The systems that manage it are integral to infection prevention, patient safety, and the overall resilience of healthcare infrastructure. From operating theatres to isolation rooms, the quality and control of air can directly influence clinical outcomes. Yet despite this critical role, the UK healthcare sector still relies on guidance rather than enforceable standards. At Mansfield Pollard, we believe it’s time for a more robust, system-wide approach.
As specialists in air management, and manufacturers of HTM 03-01 compliant air handling units, we’ve seen first-hand the benefits of rigorous design, validation, and performance assurance. We’ve also seen the confusion, inconsistency, and missed opportunities that arise when compliance is treated as open to interpretation rather than a defined benchmark.
We aren’t calling for a blanket regulation. Rather, we’re calling for clarity, collaboration, and smarter specification, especially in high-risk clinical areas where the consequences of poor ventilation are most severe.
The clinical imperative for ventilation
Ventilation in healthcare settings is a cornerstone of clinical safety. Properly designed and maintained systems ensure appropriate air change rates, pressure differentials, and filtration levels, all of which are essential to controlling airborne pathogens. In environments where patients are immunocompromised, or undergoing aerosol-generating procedures, the margin for error is slim.
HTM 03-01, the Health Technical Memorandum for specialised ventilation, provides detailed guidance on achieving these outcomes. It outlines best practice for system design, installation, validation, and maintenance. However, it remains exactly that: guidance. Crucially, it is not law. Its use of advisory language, ‘should’ rather than ‘must’, creates a grey area that may compromise patient safety.
The term ‘HTM-compliant’ is widely used across the industry, but without a formal certification framework, it is often self-declared and, as a result, inconsistently applied. In fact, there is no statutory mechanism to enforce compliance.
This ambiguity leads to significant variation in system performance across healthcare estates. Manufacturers, contractors, and estates teams may interpret HTM compliance differently. This inconsistency places undue pressure on authorising engineers, particularly those trained and endorsed by IHEEM, who are often engaged too late. By that point, systems are already installed and operational, and resolving non-compliance can be costly, disruptive, or even unfeasible.
We believe IHEEM’s role is essential, and should be strengthened to close this gap. Their authorising engineers are highly skilled professionals who uphold best practice and protect patient safety. However, they need greater support, particularly through earlier engagement in the design and specification process and stronger collaboration with manufacturers.
Industry resistance and misconceptions
Despite the clear benefits of HTM 03-01 compliance, resistance persists across several fronts. Procurement teams may view HTM compliance as a cost burden, focusing on capital expenditure rather than lifecycle value. Yet, the long-term benefits, including reduced infection risk, extended equipment lifespan, and simplified maintenance, will often far outweigh the initial investment.
Commercial pressures within the construction supply chain often lead to the selection of lower-cost alternatives. We’ve seen HTM-compliant units substituted for systems certified under Germany’s VDI 6022 standard, and whilst VDI is a respected hygiene standard in its own right, it is not equivalent to HTM 03-01. Using it as a value-engineered substitute can compromise performance in UK healthcare settings, where the regulatory and clinical context is different.
In some projects, derogation has been sought to allow the installation of non-compliant units. This practice highlights the need for clearer specification processes, and improved understanding of how ventilation standards differ, particularly where clinical risk is high.
Smaller manufacturers may view certification as exclusionary, fearing it could limit their market access. However, a tiered approach where critical areas such as operating theatres require full compliance, and non-critical zones follow guidance, can balance inclusivity with rigour.
What a certification framework
could look like
A structured certification model would not require every air handling unit in every healthcare building to be certified. That would be impractical. However, in high-risk clinical environments, certification could provide the assurance that systems are designed, installed, and maintained to a consistent and verifiable standard.
Such a framework could include design certification linked to defined performance criteria, third-party verification of installation and commissioning, and periodic operational re-certification. It would also ensure that all personnel involved, from designers to maintenance engineers, are appropriately qualified and trained.
Rather than replacing the role of authorising engineers, certification would complement it more effectively. It would provide a stronger foundation for their oversight and ensure that systems are compliant from the outset, remaining so throughout their lifecycle.
The value of certification is already well established in other sectors. In healthcare construction, BREEAM Healthcare standards are widely used to ensure sustainable building design. In manufacturing, CE marking, Eurovent Certification for AHUs, and ISO 9001 have all contributed to raising quality, improving consistency, and building trust in performance claims.
A similar model for healthcare ventilation would offer the same benefits. It would provide estates teams, contractors, and manufacturers with a clear benchmark, reducing ambiguity and supporting more consistent outcomes across the healthcare estate.
Making procurement more efficient
Certification could also unlock significant commercial and procurement efficiencies. Currently, varied interpretations of HTM 03-01 often lead to bespoke designs, extended lead times, and complex tender evaluations. A defined certification standard would help manufacturers to develop pre-approved AHU configurations, optimising production and reducing engineering variation — ultimately lowering costs through economies of scale.
Procurement teams would then benefit from clearer benchmarking, enabling like-for-like comparisons and greater confidence in performance claims. Thinking ahead to project delivery, this would be significantly more streamlined and consistent due to the reduced administrative and technical burdens of design reviews and compliance checks.
As healthcare embraces Modern Methods of Construction (MMC), including off-site modular builds, certified ventilation systems will become increasingly important. Standardised AHU certification would allow validated equipment to be integrated into Building Information Modelling (BIM) object libraries, facilitating faster design approvals, improved coordination, and fewer late-stage design changes.
This approach would reduce reliance on specialist on-site design teams and support scalable, repeatable healthcare facility models such as those being developed under the New Hospital Programme. Certification would help ensure that all ventilation components within these standardised designs meet consistent, enforceable performance levels.
Environmental performance
The move towards certification does not have to happen in isolation. It can align with wider developments in the healthcare sector, including sustainability, energy efficiency, and decarbonisation. Ventilation systems are among the most energy-intensive components of healthcare estates, accounting for up to 40 per cent of electricity consumption on some sites. Improving their performance is not only a technical priority but also a critical opportunity to accelerate carbon reduction.
A structured certification framework could offer a reliable mechanism for embedding energy performance into ventilation design and operation. This might include defined limits on Specific Fan Power (SFP), mandatory use of EC fans and low-leakage casings, lifecycle efficiency benchmarking, and automatic setback or shutdown controls during non-operational hours. While these principles are encouraged in HTM 03-01 Part A, certification would ensure they are applied consistently and evaluated against measurable outcomes.
Most importantly, this approach would directly support the NHS’s ambition to reach Net Zero emissions by 2040. By embedding sustainability and decarbonisation criteria into a formal certification process, healthcare ventilation can contribute meaningfully to national carbon targets without compromising clinical integrity or infection control.
IHEEM plays a vital role in training and accrediting authorising engineers. Their push for HTM alignment is commendable, but unfortunately there is no legislative power to enforce it. We believe IHEEM, manufacturers and air handling experts like us, must all work more closely to ensure that together we can present a connected ambition which drives forward best practice. A prime example of where this approach has been successful is the Building Engineering Services Association (BESA), which has successfully lobbied for regulatory change through collaboration with manufacturers and installers.
By partnering with manufacturers, IHEEM can shape a certification framework that’s practical, scalable, and aligned with real-world challenges, and which stakeholders are already bought into. This would enhance the credibility of HTM 03-01 and provide a more robust foundation for compliance across the healthcare estate. Together, we could ensure that ventilation systems are not only designed to best practice but installed and maintained to it as well.
From guidelines to guarantees
At Mansfield Pollard, we have built our reputation on engineering air handling systems grounded in the principles of HTM 03-01, applying its guidance rigorously across every stage of manufacture. Our commitment to quality, performance, and compliance is embedded in every unit we manufacture, and our Factory Acceptance Testing (FAT) protocols already reflect the kind of rigour a certification framework would demand.
This is not about elevating one manufacturer over another. It is about raising the bar across the entire sector. The current reliance on guidance alone creates too much room for interpretation – and with that, inconsistency. In critical care environments, inconsistency can carry unacceptable risk. Certification, where appropriate, offers a clearer path to accountability and assurance.
The future of healthcare ventilation depends on smarter specification, earlier collaboration, and stronger alignment between manufacturers and industry bodies like IHEEM. HTM 03-01 provides a solid foundation, but it’s job well begun and not job done. Now is the time to build on it, because when it comes to the air patients breathe, good enough simply isn’t good enough.