Disproportionate burden assessment: Health building note and health technical memorandum

As of September 2018, accessibility legislation states that public sector websites must publish content in an accessible format. This means making our website content ‘perceivable, operable, understandable and robust’. You can read more about how our website complies with this regulation in our accessibility statement.

The majority of health building notes (HBN) and health technical memoranda (HTM) documents have been published on our website in PDF format.  This format may not be fully accessible to users of assistive technologies.

Assessment outcome

We have assessed the requirements for providing this information as web copy (in HTML) and have concluded that to do so for HBN and HTM documents presents a disproportionate burden for the following reasons:

Target audience

The target audience for HBN and HTM documents is engineers and other NHS estates professionals who typically print the information. They also need to use some of the technical graphics at scale.

Cost and volume of resource to produce

The documents are frequently more than 100 pages long and are regularly updated. Producing all HBN and HBM publications in HTML would mean sourcing support for the NHS England web team, at additional cost.  

Benefit of greater accessibility

Conversion to HTML has been tested and results in significantly reduced quality of the technical graphics because scalable vector graphics (SVG) files cannot currently be uploaded to the website.

We have acknowledged that most HBNs and HTMs are therefore more useful and accessible to their specific audience in PDF format.

Where it is possible to convert an HBN or HBM document to HTML without lowering usability we will aim to publish in HTML.

The majority of documents will be published as PDF, acknowledging the limitations this causes to users of assistive technologies, and providing users with a contact to request alternative formats.

How long this assessment will apply

This assessment is likely to apply until the work to develop a new NHS England website is concluded and SVG files can be included in the media library. Discovery work on this project started in March 2024.

Reasonable adjustments

Under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland) we will make reasonable adjustments for people who need information in a more accessible format. You can find out more about reasonable adjustments in our Accessible Information Standard.