Draft Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2026

Caroline Johnson Excerpts

Wednesday 15th April 2026 General Committees

[Dr Caroline Johnson (Sleaford and North Hykeham) (Con)]

It is a pleasure to serve under your chairmanship this afternoon, Mr Stringer. Before discussing the regulations, I want to acknowledge their origin. The horrific Manchester Arena attack killed 22 people and injured more than 1,000 others. I express my condolences and good wishes to all those affected by that vicious attack.

Those running events such as concerts are required to comply with the law, to follow Health and Safety Executive rules, including the purple guide, and—of particular relevance to this debate—to ensure that they have appropriate medical cover. I thank Sir John Saunders for his work on the inquiry. He found very severe deficiencies in the medical cover that night.

SMG had contracted Emergency Training UK to provide medical cover. The person leading that organisation said he had a valid major incident medical management and support qualification—I am sure the Minister has done that qualification, as I have, because hospital MIMMS covers the response to a major incident. He also said that he had an Advanced Life Support Group qualification in advanced life support, but he did not. Again, that is a qualification that both the Minister and I have. I have taught on one of its courses.

This individual was not a health professional, so he was not regulated by the General Medical Council or the Nursing and Midwifery Council. He did not provide adequate training, equipment or record keeping, and he employed staff to do a job for which they were not qualified. Such events are required to have a certain level of medical cover, and although the staff he employed that night did their best, they did not have the level of medical training they should have had. He performed an inadequate risk assessment. Particularly horrifically, he had worked in the arena providing medical cover for a long time.

Of course, most of the time, all was well. However, the system, such as this individual had one, was weak, and when faced with the attack and multiple seriously injured casualties, fell apart. The consequence is that, despite the best efforts of his staff and many others who were present, a poorer quality of healthcare was given than should have been provided had he done his job properly.

Quite reasonably, that caused anger and questions. How on earth could someone be allowed to set up a service to deliver healthcare and safety provision, not through volunteers but as a company, and not provide the proper staff, training or equipment? It was either dishonest or incompetent. It was disgraceful, and the inquiry report was rightly scathing.

The report recommended that the regulation of event medical care be considered, saying that the CQC had suggested that it was the right organisation to provide that. It also recommended that the Government set a standard of medical care for different events to which individuals should be held to ensure consistency, and strongly recommended that sanctions be put in place so that people who do not comply, such as the company in this case, would be subject to criminal or civil sanctions, or both, for their actions. I was outraged when I read the report. Of course, we all want the highest quality healthcare for everybody on all occasions, but we have to consider soberly whether these regulations are the best way to achieve the outcome we all want to see.

The regulations remove exemptions for on-site healthcare at sports events and music festivals, but there is a question of scale. Manchester Arena holds up to 21,000 people, and sporting events or festivals can have many more participants and spectators. There are strong arguments that such events, which usually have commercial healthcare providers, should provide a great service with suitably qualified staff, and should face sanctions if they do not. However, not all sports events are at Wembley, Silverstone or Twickenham, and not all music events are Lost Village, Glastonbury or Manchester Arena.

What will be the effect on grassroots sport? Some small-volume events are high-risk sports and need medical cover, as the Minister suggested, but how small is too small to require healthcare? What regulation will the Government put in place for that? As the regulations also affect volunteers, will they discourage volunteering in healthcare provision? If so, will that affect the ability of sports events to take place, and how many events will be affected? The Government have admitted that they do not know the answer.

The other small peculiarity is whether medically qualified staff will need to step back in favour of non-medically qualified staff who have a first aid certificate to avoid the need for registration, which I will come to in a moment. Will cover, in some cases, be downgraded to first aid cover that, unlike TDDI cover, does not require registration? If there is such a downgrade, will it be good or bad for patients?

What is first aid? The Health and Safety (First-Aid) Regulations 1981 define it as

“cases where a person will need help from a medical practitioner or nurse, treatment for the purpose of preserving life and minimising the consequences of injury and illness until such help is obtained”,

or as the

“treatment of minor injuries which would otherwise receive no treatment or which do not need treatment by a medical practitioner or nurse”.

As the Minister said, first aid will remain exempt from registration, but it is not entirely clear whether that remains the case where it is provided by a healthcare professional. The CQC website says that first aid is exempt where it is provided by a non-healthcare professional with first aid training or by a healthcare professional who is acting in an emergency or unexpected situation, but if a person is at a sports event specifically to provide healthcare for people who might have an injury, is that an unexpected event? Does it count as first aid, or is it TDDI?

I note that many of the people who responded to the consultation said that it is not clear where first aid finishes and TDDI starts. It is important that the Government define that more clearly. If they do not, there is a risk that people will not provide healthcare when they could provide it perfectly competently, because they are concerned they do not have the registration status to do so and fear the sanctions that may be imposed, when those sanctions have been decided.

Some of this might be covered by the guidance. The recent Government scoping exercise planned 49 types of guidance, including the purple book and the green book. But it is notable that whereas the Health and Safety Executive used to publish the purple and green books or their equivalents together, they are now provided separately; the purple book costs £50 to read an online copy and the green book costs £30 to read an online copy. That might not be of any particular consequence to Twickenham, Wembley or Manchester Arena, but it is of consequence to people running very small events, whether sporting, cultural or musical.

Can the Minister say when the event healthcare standards will be published? He is asking us to vote to hold people to a standard he has not written yet. Will it be free to access? What consideration will be given to support specific courses? The Rugby Football Union, for example, provides specific courses for healthcare provision at its matches. What role will it play in event healthcare standards? What provision will be made for children? Children are not just small adults and specific healthcare considerations may apply.

Another issue, which the Minister himself touched on, is whether the CQC is fit for purpose. The Secretary of State said that it is not. I have not heard the Minister say what additional resources will be provided to the CQC to deliver the additional regulations. There is a difference between healthcare providers in a muddy field or on the side of a hill compared with medical care providers in a hospital with a full suite of equipment. What extra training will the CQC need to regulate this? What will be provided? Is the Minister confident that it can be done, particularly in time for the deadlines imposed by the regulations we are being asked to vote for today, given that the event healthcare standard has not even been written or published yet, and given the Government’s propensity to delay the publication of things such as the workforce plan, which was due over a year ago and has still not been published?

Another issue is mountain rescue. I should declare an interest as a former member of a mountain rescue service—the Minister is smiling. The service follows insurance licensing rules and the purple book. It also has training for remote rescue medical technicians that is governed by the Mountain Rescue England and Wales medical sub-committee under the auspices of the University of Lancashire. It has expressed significant concerns. First, if there is a healthcare professional on the team, what effect do these regulations have? Will they be able to carry the controlled drugs that they are able to provide for the rescue services if they need to administer healthcare on the side of the mountain? These are volunteers, not paid employees. Who will do the paperwork, who will pay for it and who will fund it? Will the Government consider exempting mountain rescue services and volunteers from the charges?

Will England be a less attractive place for events? The costs and numbers appear far higher than the Government estimate. Sports bodies have done a survey that suggests that almost half of doctors will withdraw from doing voluntary events because of the regulations. What about the wider costs for sports and events? They currently face costs for national insurance, employment costs, rising inflation and Martyn’s law, and now there will be the cost of these regulations. What sanctions will there be? It will be against the law to breach the regulations, but what will happen to people who do?

What will be the effect on international sporting events? Some international teams bring their own medical teams with them. The individual medical team applies for temporary GMC registration, usually a couple of months before they come over for events. They may provide TDDI to those in their care. Will that be affected by the regulations? Will they need to register or not? Physiotherapists too have asked whether the care they provide will count as TDDI or as first aid. Will they need to register?

In the previous Government’s assessment in 2023, the cost was put at £1,200 per registration and an ongoing £1,900 per annum. What will be the effect of meeting the event healthcare standard on the smallest events and how will volunteers manage those costs?

The Government have created an exemption for transport within a site. I want to understand why. For example, my husband was injured in an accident at Silverstone a couple of years ago. He received healthcare in the car, and then as he was being transported to the ambulance building within the complex. He was given excellent care, for which I am very grateful. The helicopter then came and took him to Coventry hospital. Why have the Government chosen to regulate the on-site care that a person receives in the vehicle they were driving, for example, and the care provided in the hospital, but not in the gap between the two? That seems a little peculiar to me. The Minister has obviously thought about it carefully, and I wonder what reason he will give.

The healthcare professional in charge at some events can be quite junior. I went to an event with 18,000 people and met the medical team there, which was led by a doctor three years post qualification. That seemed quite a junior doctor to be covering a whole medical team. I also noted that the responsible officer was his employee. Although there is no rule that stops a responsible officer being an employee, I should explain that the responsible officer is the doctor who signs off on one’s annual appraisal and General Medical Council revalidation every five years. Clearly, there is a conflict of interest if a person’s boss is asking to be signed off. Can the Minister please look at that to see whether it is appropriate a responsible officer to be an employee, as that was also happening in an event setting?

Although I think the draft regulations are born from a good place with an important motivation, and it is important that they are done correctly, we do not currently know their cost, effects, scope or standards, including their effects on grassroots event boards. We therefore cannot have confidence that they will achieve the goal we want. Everyone in this room—everyone in the country—wants everyone to receive the best possible healthcare, but I am not convinced at this stage that the Government have really got this right.

--- Later in debate ---

[Dr Ahmed]

My hon. Friend raises an excellent point; I am very happy for the CQC to take that away and answer her specific question. On the issue of what constitutes first aid or more complex medical care, all of us who have been medical cover at events have sometimes come across the incongruous situation where being a medically qualified doctor is sometimes not enough to provide first aid. Those incongruities have existed for as long as I have been in practice, and I do not think the regulations particularly change that. It is often down to individuals’ interpretation of first aid, as well as their insurance cover, and I am sure that we do not want to overly complicate this matter.

[Dr Johnson]

Will the Minister give way?

[Dr Ahmed]

The hon. Lady knows that I often indulge her interventions, but not today. These regulations are a response to a public inquiry and are designed to ensure that the CQC has the scope and oversight of events and arenas. It is for the CQC over the next 15 months to provide some of these definitions and clarity, and they are absolutely the right people to do it. On that basis, I ask colleagues to support this very necessary measure to protect those the people we were elected to serve.

Question put.