What do you actually need to have in place to run a safe and compliant mHBOT facility?
Even though mild hyperbaric oxygen therapy isn’t currently subject to specific UK regulation, facilities still have important legal responsibilities under general health and safety law. From staff training and emergency planning to maintaining proper documentation, this post outlines the practical steps every operator should take — including what to keep in your compliance folder to ensure you’re covered.
Important Disclaimer: Guidance, Not Legal Advice
The information provided below is intended as general guidance to help mild hyperbaric oxygen therapy (mHBOT) facilities understand how key UK health and safety regulations may apply to their operations. While we strive to offer accurate and practical insights, we are not a regulatory authority, and this content should not be taken as legal or compliance advice.
It is ultimately the responsibility of each business to assess its own setup, risks, and obligations, and to ensure full compliance with applicable laws. We strongly recommend that all facility operators consult official regulatory sources — such as the Health and Safety Executive (HSE) — and seek guidance from qualified health and safety professionals where needed.
1.The Health and Safety at Work Act 1974 (HSWA)
What it means:
This is the foundational UK health and safety law. It places a legal duty on employers (including therapy providers) to ensure, so far as is reasonably practicable, the health, safety, and welfare of employees and anyone affected by their operations — including clients.
How it applies to mHBOT facilities:
- You are legally responsible for the safety of clients using your chambers, and for the wellbeing of staff operating them.
- You must provide a safe environment, safe equipment, and appropriate training and supervision.
What your facility should do:
- Create and maintain comprehensive safety protocols for chamber operation. We cover this in our Oxygens equipment training – you must ensure you strictly follow our equipment usage instructions.
- Ensure staff are trained in operating procedures, emergency actions, and client care. Full training is provided upon installation. All business orders have unlimited access to our online theory course – please contact us for extra places for your staff.
- Keep records of training, maintenance, and incidents.
- Ensure your premises are clean, hazard-free, and fire-safe.
2. PUWER — Provision and Use of Work Equipment Regulations
What it means:
PUWER applies to any equipment used at work — from hyperbaric chambers to oxygen concentrators and control panels. It requires that equipment is safe for use, properly maintained, and operated only by trained, competent people.
How it applies to mHBOT:
- Your hyperbaric chamber is work equipment under PUWER.
- You must ensure that it is suitable, safe, and regularly maintained.
What your facility should do:
- Conduct and document pre-use checks, periodic servicing, and annual inspections.
- Maintain an equipment logbook noting servicing, faults, and repairs.
- Ensure only trained operators run sessions.
- Keep manufacturer manuals and follow maintenance schedules.
3. COSHH — Control of Substances Hazardous to Health
What it means:
COSHH is designed to protect workers and clients from hazards associated with substances. While oxygen itself is not toxic, it is a powerful oxidiser and poses a serious fire risk when present in higher-than-normal concentrations.
Oxygen Use and COSHH Considerations
Our chambers are pressurised using ambient room air (not oxygen), delivered continuously by a compressor system. This maintains safe oxygen levels in the chamber by refreshing the internal atmosphere throughout the session, rather than allowing it to become stagnant or enriched with excess oxygen.
While the chamber itself is not filled with pure oxygen, supplemental oxygen is delivered via a mask during treatment. This introduces a localised oxygen-enriched environment. For this reason, and in accordance with COSHH fire risk control measures, it is essential to display appropriate signage (e.g. “Oxygen in Use”) whenever a session is active.
We also advise against the use of aerosols, air fresheners, perfumes, or any flammable products in or near the chamber environment.
Additionally, smoking, vaping, or open flames must be strictly prohibited in the chamber room or adjacent areas. These precautions are part of a responsible approach to minimising ignition risks in an oxygen-enriched setting, in line with COSHH and general fire safety practices.
4. General Risk Assessment and Emergency Procedures
What it means:
Under the Management of Health and Safety at Work Regulations (1999), employers must carry out risk assessments, implement preventative measures, and establish clear emergency procedures.
How it applies to mHBOT:
- You must identify all potential hazards — pressure-related, fire, entrapment, fainting, etc.
- You must plan for medical emergencies, power loss, fire, and chamber decompression failures.
What your facility should do:
- Create a detailed risk assessment, review it regularly, and keep it accessible.
- Develop emergency action plans — including how to depressurise a chamber quickly and safely (covered in our equipment training).
- Know where the emergency stops are located and how to use them, have fire alarms in the room, and observe users via the windows and ensure two-way communication in chambers.
- Conduct staff drills and document them.
- Have a first aid plan, including access to trained responders and oxygen shut-off protocols.
Final Recommendations
To ensure full compliance and demonstrate duty of care:
- Maintain a health and safety policy tailored to mHBOT operations.
- Train and document every staff member’s role, including emergency actions.
- Keep a compliance folder with:
- Equipment manuals and service logs
- Risk assessments
- COSHH assessments
- PUWER checklists
- Staff training records
- Emergency procedures
At Oxygens, our role is to supply high-quality mild hyperbaric oxygen therapy (mHBOT) equipment — including chambers and oxygen concentrators — designed for safe and effective operation. While we do not provide regulatory services or manage compliance on behalf of facilities, we encourage all clients to take responsibility for maintaining accurate equipment manuals, service logs, risk assessments, COSHH documentation, PUWER records, staff training logs, and emergency procedures as required by UK law. We’re committed to supporting you with clear product information and safe operating guidance, so you can confidently meet your own health and safety obligations.