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HTM 04-01 and D 08: how TMVs should be tested
If you've been told to test your TMVs "to HTM 04-01", this is what that actually means. We've read the documents so you don't have to, and linked the originals so you can check.
- Fail-safe check5 s · 60 s · 120 ml
- Restorationwithin 2°C
- First tests6–8 & 12–15 weeks
- Strainersat least annually
Which documents are we talking about?
HTM 04-01, Safe water in healthcare premises, is the Department of Health's guidance for water systems in NHS and other healthcare buildings. It comes in three parts: Part A covers design, installation and commissioning; Part B covers operational management; Part C deals with Pseudomonas aeruginosa in augmented care units.
Alongside those sits a supplement, Performance specification D 08: thermostatic mixing valves (healthcare premises), currently the 2017 edition. Most of D 08 is laboratory testing that manufacturers go through to get a valve TMV3 certified. The bit you need on site is Chapter 11, commissioning and in-service tests, plus Annex F on how often to test.
Part B ties them together. It says thermostatic mixing devices should only go in where a risk assessment shows they're needed (7.40), and that their temperature settings and operation must be checked regularly in line with Chapter 11 of D 08 (6.36 and 7.41). It also points out that local water quality will affect how often valves need maintenance.
Does it apply to you?
Strictly, HTM 04-01 is written for healthcare premises. If you run an NHS site or a private hospital or clinic, your Water Safety Group will expect it. Care homes, supported living, schools and housing providers aren't directly covered. Plenty of them still use the D 08 test as their method, because it's clear and repeatable and an inspector or insurer will recognise it. HSE's HSIS6 also says Type 3 valves should be used in health and social care when TMVs are replaced or newly installed.
Maximum set temperatures by outlet
These are the maximum mixed water temperatures D 08 allows at the point of discharge for each valve designation. A lower setting is fine where your risk assessment calls for it.
| Outlet (designation) | Maximum | Notes |
|---|---|---|
| Bidet (B) | 38°C | The lowest setting, for direct contact with sensitive skin. |
| Shower (S) | 41°C | Whole-body exposure, often with nowhere quick to step out of the flow. |
| Washbasin (W) | 41°C | Assumes hands are washed under running water. |
| Bath, 44°C fill (T44) | 44°C | The usual bath setting. Check the water before anyone gets in. |
| Bath, 46°C fill (T46) | 46°C | Only where the bather is always supervised by a competent person, such as a nurse or care assistant. |
| Bath/shower diverter (D44, D46) | 44 / 46°C | Bath fill as above, with the shower outlet held at 41°C. |
D 08 Table 18 sets the supply conditions for normal use: hot water at 55°C or more, cold at 20°C or less, flow pressures of 1 to 5 bar for high pressure valves or 0.2 to 1 bar for low pressure, and no more than 10 bar static. If your supplies sit outside that, no amount of adjusting the valve will make it behave.
Commissioning: setting the baseline
Commissioning (D 08 clause 11.1) is the first test, done when a valve is installed or replaced. The engineer checks the valve is right for the outlet and the supplies are suitable, sets the mixed temperature and makes sure the pipework is free of debris. They then run the same sequence as an in-service test, below. Those first readings are the baseline every later test is compared with, so if your valves were never commissioned on paper, the first service effectively becomes the baseline. There's more in our post on commissioning a new TMV.
The in-service test, step by step
Clause 11.2 of D 08 sets out the routine test. Its purpose, in the document's words, is to maintain assured performance and keep records of how the valve performs. This is the sequence we follow at each valve:
- Check the supplies. Record the hot and cold supply temperatures next to the valve, and the pressures where they can be measured.
- Measure the mixed temperature. Run each outlet at maximum available flow and record the temperature at the point of discharge. If needed, adjust it, but never above the Table 17 maximum.
- Isolate the cold supply. Shut off the cold to the valve and watch the outlet.
- Apply the 5 second rule. If water is still flowing after 5 seconds, collect it in a measuring jug for 60 seconds. More than 120 ml means the valve needs recommissioning or service work.
- Restore and re-measure. Turn the cold back on, wait 15 seconds and record the mixed temperature again.
- Apply the 2°C rule. That reading should be within 2°C of the one taken in step 2. If it isn't, recheck the supplies and recommission the valve to the manufacturer's instructions.
- Check the strainers and isolators. Note whether strainers and check valves are clean and isolation valves are fully open.
- Record and set the next date. Write down the final temperature, any work done and when the next test is due.
If a valve fails, the usual causes are scale, debris in the strainer or a tired cartridge. Our post on what to do after a failed fail-safe test goes through the options.
How often to test: letting the valve set the interval
Annex F is "informative", meaning it's a recommended starting point rather than a fixed rule. Your Water Safety Group or risk assessment can change it. The idea is simple: test early, see how much the valve moves, then space tests out only as far as the valve has shown it can cope.
| What the early tests show | Next in-service test |
|---|---|
| First test | 6 to 8 weeks after commissioning |
| Second test | 12 to 15 weeks after commissioning |
| No significant change (about 1°C or less) at either test | 24 to 28 weeks after commissioning |
| Small change (1 to 2°C) needing adjustment at one of the tests | 24 to 28 weeks after commissioning |
| Small changes needing adjustment at both tests | 18 to 21 weeks after commissioning |
| Significant change (more than 2°C) needing service work | 18 to 21 weeks after commissioning |
| After the first two or three tests | Set future intervals to what previous tests show the valve can manage with no more than a small change |
Separately, Part B's maintenance checklist and HSG274 Part 2 both say TMV strainers and filters should be inspected, cleaned, descaled and disinfected annually or on a frequency set by the risk assessment, taking the manufacturer's advice into account. In practice most stable sites end up on six-monthly or annual servicing, and hard water pushes that towards six-monthly.
What D 08 expects you to write down
D 08 includes a sample test record sheet. Whether you use it or your own format, these are the things it asks for at every valve.
- Valve reference, location, outlet type, installation date and blend setting
- Hot and cold supply temperatures and pressures, now and last time
- Mixed temperature at maximum flow
- Fail-safe result: flow after 5 seconds, and volume in 60 seconds if so
- Temperature after the cold is restored, and the deviation from the initial and previous results
- Strainers and check valves clean, isolation valves fully open
- Final temperature, the engineer's name and the next test date
Where Legionella fits in
TMVs solve one problem and can create another. The water after the valve is warm, and HTM 04-01 Part B warns that pipework downstream of TMVs can encourage the growth of waterborne pathogens. HSE's HSG274 Part 2 asks for TMVs to be as close to the outlet as possible, ideally built into the tap. It also warns that one valve feeding several outlets increases the risk. And it says a TMV that isn't needed should be removed. Part B adds that TMVs shouldn't be fitted in series with mixing taps.
So TMV testing belongs in your Legionella written scheme under ACOP L8, alongside temperature monitoring and flushing of little-used outlets. We'll flag hot or cold supplies out of range, long blended runs and redundant valves when we see them.
HTM 04-01 and D 08 questions
Is D 08 the same thing as TMV3?
Not quite. D 08 is the NHS performance specification, and TMV3 is the third-party certification scheme that tests valves against it. A TMV3-certified valve has passed D 08's laboratory tests for the applications listed on its certificate. Chapter 11 of D 08 then tells you how to commission and test it once it's installed.
Do we have to follow the Annex F intervals exactly?
No. Annex F is labelled informative, so it's a recommended starting point. D 08 says your Water Safety Group's risk assessment can change the frequency, for example because of supply conditions or water quality. What you do need is a reasoned interval, written into your scheme and backed by test results.
Our valves were fitted years ago and never tested. Where do we start?
Treat the first visit as recommissioning. Each valve gets a full service and test, and the readings become your new baseline. Then follow the Annex F pattern from there, with early retests on any valve that needed significant work. If you don't know how many valves you have, we can build an asset register on the same visit.
Is a thermometer reading at the tap enough?
It's a useful weekly or monthly check, and Part B says staff must check bath water with a thermometer before assisting someone in. But it isn't an in-service test. The D 08 test also includes the supplies, the cold isolation and the restoration check. Those are what prove the valve will protect someone if something upstream changes.
Does a TMV3 valve need testing more often than a TMV2?
The certification doesn't set the frequency, how the valve performs does. In practice TMV3 valves tend to be in settings with vulnerable users and stricter risk assessments, so they're often tested more often. A TMV2 valve in a care setting where TMV3 is expected should be reviewed for replacement anyway.
Does HTM 04-01 apply in Scotland and Wales?
Scotland and Wales publish their own versions: SHTM 04-01 from NHS Scotland, and WHTM 04-01 with its own D 08 supplement from NHS Wales. The approach is very similar, but if your site is there, check your local edition, as figures and wording can differ.
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