Using non-certified restraint training: risks, requirements and safer options

When a service chooses restraint training that is not certified to the recognised national standards, the impact is rarely limited to the training room. It can affect regulatory confidence, commissioning decisions, incident response, insurance, staff competence, and most importantly the safety and rights of the people you support. This article sets out what can go wrong, how to assess the risk sensibly, and how to put a practical improvement plan in place.

The focus here is not about naming or shaming any provider. It is about due diligence and governance: if restraint is ever used, you need to be confident that your training approach is ethical, proportionate, defensible, and consistent with current expectations across health and social care.

Start with the real question: what is the organisation trying to achieve?

Many organisations begin by asking which badge a course carries. A better starting point is to be clear about the outcomes you need:

• Reduce the likelihood of people reaching crisis point through early, person-centred support.
• Ensure staff can respond safely when risk escalates, using the least restrictive option for the shortest possible time.
• Protect people’s rights and dignity through a values-led approach, not a technique-led one.
• Be able to evidence competence, oversight, and continuous improvement to regulators and commissioners.

If those outcomes are your aims, the details of certification and standards become much easier to evaluate.

What can happen if restraint training is not certified to recognised standards?

Non-certified training is not automatically unsafe. However, it can create avoidable organisational risk because you may be unable to demonstrate that the content, trainers, assessments and governance meet current expectations. The risk is highest in CQC regulated settings and where services are NHS commissioned.

1) Regulatory and commissioning risk

The Restraint Reduction Network (RRN) explains that since April 2021, the Care Quality Commission has expected services across health and social care to use training in restrictive practices that is certified as complying with the RRN Training Standards, and that not doing so is likely to be a breach of CQC Regulation 18 on staff training (RRN guidance on statutory requirements).

The Local Government Association briefing for commissioners also states that from April 2021, CQC would expect services across health and social care to only use training in restrictive practices that is certified as complying with the RRN training standards, and advises commissioners to check certification when contracting (LGA reducing restrictive practice briefing).

In practice, this can show up as:

• Reduced confidence in your governance if an inspector asks how you assure the quality and safety of restraint-related training.
• Challenges during tendering or contract monitoring, particularly where commissioners specify RRN-aligned training.
• More intensive action planning after inspection findings about training, competence, or oversight.

2) Safeguarding and incident-response risk

If a restraint incident results in injury, a safeguarding concern, or a complaint, training is often scrutinised. You may be asked to evidence:

• Why staff were trained in particular techniques and who independently risk assessed them.
• How you ensured the approach prioritised prevention, de-escalation and recovery, not just physical skills.
• How competence was assessed and refreshed, and how you used data to reduce future incidents.

The RRN Training Standards set out a rights-based framework and emphasise prevention, de-escalation, reflective practice and minimising restrictive interventions (RRN Training Standards (accessible PDF)). If your training is not aligned, it can be harder to show that your programme covers what good practice expects.

3) Workforce confidence and skill fade

Even well-intentioned training can fall short if it is inconsistent, overly technique-focused, or lacks robust assessment. Common knock-on effects include:

• Staff feeling uncertain about what is permitted, when to act, and how to document decisions.
• Inconsistent responses across shifts, leading to avoidable escalation.
• Weak post-incident review and learning, so patterns repeat.

4) Reputational and family confidence risk

Families, advocates and commissioners increasingly expect transparency about how a service keeps people safe while respecting dignity and rights. If you cannot clearly explain your approach to restraint reduction and training assurance, it can erode trust even when care is otherwise strong.

A practical decision framework: should we keep, improve or replace the training?

When leaders discover their training is not certified, the most helpful response is a structured decision rather than a rushed switch. Use the framework below to decide whether to keep the programme with improvements, or replace it.

Step 1: Clarify your setting and expectations

Start by mapping the environment you operate in. For example:

• Are you CQC registered? Are you providing regulated activities that place you within CQC expectations on staff training?
• Are you NHS commissioned or delivering services aligned to NHS contract requirements?
• Are you supporting adults, children, or both? Do you have a mix of community and residential provision?
• What do your commissioners specify in contracts or service specifications?

This is also a good moment to brief senior leaders on what your current training can and cannot evidence. If you want a clear explanation of the certification landscape, our overview of BILD ACT certification can help you frame internal discussions.

Step 2: Conduct a gap analysis against the RRN Training Standards

Whether you plan to change provider or not, a gap analysis is useful because it converts a vague concern into specific actions. Use the standards as a checklist across four areas:

• Pre-delivery processes: training needs analysis, independent risk assessment of techniques, accessible information, responding to concerns.
• Curriculum content: rights-based framework, decision making, prevention, de-escalation, non-restrictive strategies, and only then restrictive strategies when needed.
• Post-delivery processes: competence assessment, record keeping, evaluation, quality assurance and refresher training.
• Trainer standards: competence, professional development, and safety processes.

The RRN standards describe training as a quality assurance tool designed to facilitate culture change, not just technical competence (RRN Training Standards (accessible PDF)). Use that lens when reviewing your materials: if most of the time is spent on holds and releases, that is a signal to rebalance.

Step 3: Check technique risk assessment and proportionality

Any technique taught should be suitable for your population, environment and staffing, and it should be independently risk assessed. Ask:

• Which techniques are included, and why are they necessary in your setting?
• What is the anticipated frequency of use, and how do you plan to reduce it?
• How is breathing, positional risk and vulnerability managed?
• How do you ensure the response is proportionate and the least restrictive option?

If you provide services for children and young people, these questions become even more important. You may find it helpful to compare approaches across age groups using our information for children’s services.

Step 4: Review governance: competence, refreshers, and data

Ask for evidence on how competence is assessed and maintained. If your current provider cannot offer robust assessment and refresher pathways, you are exposed regardless of whether staff enjoyed the course.

Build a simple governance pack that includes:

• A training matrix by role, with refresher frequency linked to risk and exposure.
• Competence assessment approach (including what happens if someone is not competent).
• Post-incident review template that captures decision making, de-escalation attempts, proportionality and learning.
• Monthly incident data review focusing on reduction, not just reporting.

Step 5: Decide the route forward

Once you have your gap analysis, choose one of three routes:

• Keep and improve if the training is broadly aligned, can be strengthened quickly, and you can evidence safety and governance.
• Transition if the current training is weak but you need time to procure an alternative. Use a time-limited action plan with clear milestones.
• Replace if the programme is technique-heavy, lacks independent risk assessment, lacks robust competence assessment, or creates contract and inspection vulnerability.

How to reduce risk quickly while you plan longer-term change

Leaders often worry that changing training takes months. You can still reduce risk immediately with sensible interim steps.

Introduce an immediate “restraint reduction” expectation

Make it explicit that physical restraint is a last resort and that the service is actively working to reduce its use. This should include:

• Clear definitions and consistent recording of any restrictive practice.
• De-escalation and early support as the default response.
• Management oversight of any incident where restrictive practice is used.

Strengthen post-incident support and learning

Ensure every incident triggers a supportive debrief for the person and staff, and a review that focuses on prevention and unmet need. The LGA briefing highlights that restrictive practice can cause trauma and must be followed by therapeutic support and review (LGA reducing restrictive practice briefing).

Invest in prevention skills alongside physical safety skills

If your current training is mainly reactive, balance it with training that builds prevention and de-escalation capability. This is also a good point to review your approach to reducing the need for restraint in the first place, for example through restraint reduction training and wider team practice improvements.

CTA: If you want a structured gap analysis template and a clear action plan for your setting, speak to our team about physical intervention training options that prioritise prevention, dignity and safety.

Common misconceptions to avoid

“Ofsted requires BILD ACT certification”

Ofsted and the Department for Education focus on safe practice, safeguarding, staff competence, and the rights and welfare of children. They do not require a particular certification badge in the way some health and social care expectations do. If you operate in settings inspected by different regulators, build a clear compliance map rather than assuming one regulator’s expectations apply everywhere.

“Certification means no restraint will ever happen”

Certification is not a guarantee that restraint will never be used. It is a way to show that where restrictive intervention is part of training, the programme meets a recognised benchmark and supports a reduction culture with strong safeguards.

“We only need to change after an incident”

If you wait until something goes wrong, you lose the chance to shape the narrative and demonstrate proactive leadership. A documented improvement plan, backed by data and governance, is far easier to evidence before an incident than after one.

A simple checklist leaders can use in procurement or renewal

• Can the provider evidence certification against the RRN Training Standards where applicable?
• Is there a clear training needs analysis linking roles to risk and techniques taught?
• Are techniques independently risk assessed and appropriate to our population and environment?
• Does the curriculum prioritise prevention, de-escalation and recovery, not just physical holds?
• How is competence assessed, recorded and refreshed?
• What quality assurance and feedback processes are in place?

CTA: If you are reviewing contracts this quarter, we can help you translate these checks into tender questions and evidence requirements so you can compare providers on quality, not marketing.

FAQ

Does using non-certified restraint training automatically breach regulations?

Not in every context. The risk depends on your setting, regulator, and commissioning requirements. In CQC regulated health and social care settings, expectations around certified training are clear and you should be able to evidence how your programme meets recognised standards and staff competence requirements.

What evidence should we keep to show our training is robust?

Keep a training needs analysis, curriculum outline, trainer competence evidence, technique risk assessments, competence assessment records, refresher schedules, and minutes showing how incident data leads to improvement actions.

How quickly can we move to a safer, more defensible position?

Many services can improve governance within weeks by tightening recording, strengthening reviews, and clarifying expectations. Changing a training provider can take longer, but you can still demonstrate an active improvement plan while procurement runs.

What if we support both adults and children?

Build a single values-led framework with tailored operational procedures by setting. Your training needs analysis should reflect different risks, environments and legal frameworks, while keeping the same core focus on prevention, dignity and proportionate responses.

Where can we learn more about safer practice when restraint may be used?

Explore our resources on reducing restrictive practice and consider structured training that emphasises prevention alongside safe physical skills.

CTA: If you would like a confidential review of your current training approach, policies and incident governance, contact us to discuss what a proportionate improvement plan could look like for your service.