Crack Down on Unregulated Cosmetic Procedures

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Crack Down on Unregulated Cosmetic Procedures


The Government has confirmed its intention to introduce a licensing regime for non-surgical cosmetic procedures, including Botox and fillers. These are procedures that, if improperly performed, have the potential to cause harm, according to the announcement from the Department of Health and Social Care.

The Department said that an amendment to the Health and Care Bill will give the Secretary of State for Health and Social Care powers to introduce licensing to ensure consistent standards for those carrying out non-surgical cosmetic procedures, as well as hygiene and safety standards for premises where they are offered.

“Although the majority of the aesthetics industry shows good practice when it comes to patient safety, this step will ensure consistent standards and protect individuals from those without licences, including from the potentially harmful physical and mental impacts of poorly performed cosmetic procedures,” the announcement said.

Health and Social Care Secretary Sajid Javid said: “While most of those in the aesthetics industry follow good practice when it comes to patient safety, far too many people have been left emotionally and physically scarred after botched cosmetic procedures.

“I am committed to protecting patient safety by making it an offence for someone to perform these cosmetic procedures without a licence.

“We’re doing all we can to protect patients from potential harm, but I urge anyone considering a cosmetic procedure to take the time to think about the impact on both their physical and mental health and ensure they are using a reputable, safe and qualified practitioner.”

Will Licensing Go Far Enough?

Licensing was welcomed in principle by the British Association of Aesthetic Plastic Surgeons (BAAPS). “In general, it is a positive move but it is not clear who would be eligible for a license, and that is the key thing,” said BAAPS council member Nora Nugent.

Mary O’Brien, president of BAAPS, said: “There is a lot of scope to improve the current framework. We have campaigned for many years to highlight the loopholes that exist and can cause significant harm to the public when non-surgical and surgical treatments are delivered by those who are not appropriately trained and not held accountable by a professional body. The question is does this proposal go far enough?”

The British Beauty Council described the crackdown on unregulated cosmetic injectables as “a huge step forward”. Chief Policy Officer Victoria Brownlies said: “The commitment from Government to tackle this thorny issue is a huge step towards legitimising the professionalism of our industry – something that we have been working to achieve since our inception three years ago. We are continuing dialogue with the Department for Health and Social Care together with the Joint Council for Cosmetic Practitioners (JCCP) and organisations within personal care to make sure any new regulation succeeds in driving up standards and protects the public from harm. There is a lot of work ahead, but we remain committed to tackling it head on.”

Ashton Collins, director of Save Face, which operates a national register of accredited non-surgical cosmetic practitioners, recognised by the Government, the Department of Health, NHS England and The Care Quality Commission, said: “We commend the Government for seeking to introduce additional safeguards to protect the public.”

However, she told Medscape UK: “We have raised concerns about the possible unintended consequences of implementing new legislation when the existing regulatory framework is flawed and is not enforced. There are laws in place currently that ought to safeguard the public from being injected with unlicenced medicines and from being given Botox injections without a valid prescription, but both issues are rampant and not enough is being done by the regulators to stop it.”

“It is not yet clear how the scheme would regulate the practitioners who pose the greatest threat to public safety. Our data demonstrates there are thousands of practitioners that only operate on social media and offer treatments in people’s homes. Often these practitioners don’t disclose their full names, have no fixed address, purchase products over the internet and are uninsured and untraceable.

“We stand firm on our position that injectable treatments should only be carried by trained healthcare professionals and we will continue to offer our members a robust regulatory model upon which they can differentiate themselves from the wider beauty industry.”

Social Media Influences

Minister for Patient Safety Maria Caulfield said: “The spread of images on social media has contributed to an increase in demand for cosmetic procedures such as Botox and fillers. While these can be administered safely, we are seeing an unacceptable rise in people being left physically and mentally scarred from poorly performed procedures.”

“Today’s amendment is the next step on the road to effective regulation of non-surgical cosmetic procedures in England.”

The move follows recent legislation to make it illegal to provide such cosmetic treatments to under 18s, and to ban adverts for cosmetic procedures that target under 18s, embracing all forms of media, including social media, influencer advertising, and traditional advertising.

In addition, ongoing work with the Medicines and Healthcare products Regulatory Agency (MHRA) is looking to bring certain devices, including  dermal fillers without a medical purpose, into scope of medical device regulations. Responses from a public consultation on this, which ran to November 25, 2021, are currently being analysed and a formal response is awaited.

The scope and details of the cosmetic procedure licensing scheme are also subject to public consultation, details of which will be set out in due course.



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