S136 Commissioner Guide: Mental Health Transport Standards

What is Section 136?

Section 136 of the Mental Health Act 1983 (as amended by the Mental Health Units (Use of Force) Act 2018 and the Police, Crime, Sentencing and Courts Act 2022) gives police officers the power to remove a person from a public place to a Place of Safety when they appear to have a mental disorder and to be in immediate need of care or control.

The purpose is to allow the person to be examined by a registered medical practitioner and interviewed by an Approved Mental Health Professional. The maximum period of detention under S136 is 24 hours, extendable to 36 hours with medical authorisation.

The role of specialist transport is to convey the detained individual safely and with dignity from the point of detention to the designated Place of Safety — typically a health-based S136 suite rather than a police custody suite.

Why Specialist Transport Matters

Transporting a person detained under S136 is fundamentally different from standard patient transport. The individual may be acutely unwell, distressed, and in some cases physically resistant. Poorly managed transport journeys are a significant source of clinical risk, complaints, and serious incident reports across NHS trusts.

NHS England's Mental Health Crisis Care Concordat (2014) and subsequent Serenity Integrated Mentoring guidance emphasise that transport should be provided by trained healthcare professionals in a clinical vehicle — not in police vehicles except where risk necessitates a joint response.

Benefits of specialist clinical S136 transport:

• Reduced trauma from inappropriate restraint or police custody detention
• Better patient experience during an acute mental health crisis
• Lower risk of serious incidents during conveyance
• Clearer clinical accountability and documentation
• Improved handover quality at the Place of Safety

Clinical Standards for S136 Transport

A compliant S136 transport provider should meet the following baseline standards, drawn from NHS England guidance, CQC inspection frameworks, and JRCALC clinical guidelines:

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  Minimum crew qualification: All crew undertaking S136 conveyance should hold, at minimum, Mental Health First Aid (MHFA) certification. Ideally at least one crew member per vehicle should hold a Level 3 Award in Mental Health (or equivalent), with training updated annually.
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  De-escalation training: Crews must be trained in verbal de-escalation and trauma-informed approaches. Physical restraint should only be used as a last resort and must be documented.
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  Restrictive practices: The provider must have a written policy on use of force and restraint, aligned to the Mental Health Units (Use of Force) Act 2018. Records of any restrictive intervention must be maintained.
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  Vehicle standards: S136 vehicles should have a clinical compartment that is calming, secure and fit-for-purpose. Observation windows between cab and patient compartment are strongly recommended. Seatbelt extenders, anti-ligature fittings, and accessible medical kit are minimum requirements.
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  Risk assessment: A dynamic risk assessment must be completed prior to and during the journey. This should consider the patient's current presentation, known history, and environmental factors.
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  Communication: The provider should have a direct communication line to the receiving Place of Safety to provide advance warning of arrival, estimated time, and clinical status.
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  Documentation: A patient clinical record must be completed for every S136 journey, including observations during transport, any interventions, and handover details. This record becomes part of the clinical chain of care.

Response Time Expectations

There is no nationally mandated response time standard for S136 transport, but NHS England's guidance and ICS commissioning frameworks generally expect:

• Category A (custody/high-risk setting): 30–45 minutes from point of request
• Category B (standard Place of Safety handover): 60–90 minutes
• Out-of-hours: Providers should maintain 24/7/365 capacity with equivalent response standards

Commissioners should request evidence of actual response time performance over a rolling 12-month period, broken down by geography and time of day — not just average figures.

Crew Qualifications — What to Ask For

When evaluating a provider, request documentary evidence of crew qualifications for all staff deployed on S136 work. As a minimum, look for:

• Mental Health First Aid (MHFA England or equivalent) — refreshed every 3 years
• Safe Handling and Restraint (PMVA, MAPA, or NFPS accredited) — refreshed annually
• Basic Life Support (BLS) — refreshed annually
• Enhanced DBS check — renewed every 3 years
• Safeguarding Adults and Children — Level 2 minimum, Level 3 recommended for clinical leads
• Conflict Resolution — specific to healthcare settings
• First Aid at Work (FAW) or Emergency First Aid at Work (EFAW)
• Mandatory training compliance rate — should be above 95% across the workforce

Governance and Quality Assurance

A quality provider will operate a robust governance framework for S136 work. This should include:

• Named clinical lead with responsibility for S136 operational standards
• Regular clinical supervision for crews undertaking mental health transport
• Post-incident review process for any adverse events, near-misses or complaints
• Quarterly reporting to commissioners including incident data, response times and patient feedback
• Integration with local S136 pathway governance groups and Place of Safety meetings
• Evidence of participation in ICS mental health crisis pathway reviews

CQC Registration Requirements

Any provider carrying out S136 transport must be registered with the Care Quality Commission (CQC) under the Ambulance Service regulated activity. Verify the provider's registration status and most recent inspection rating at cqc.org.uk/care-services.

The provider's CQC registration should specifically cover the regulated activity of Transport Services, Triage and Medical Advice Provided Remotely and/or Treatment of Disease, Disorder or Injury, depending on the clinical level of service commissioned.

Health Connections CQC Provider ID: 1-12389332536.

12-Point Evaluation Checklist

Use the following checklist when evaluating S136 transport providers during procurement or contract review: