At the end of February 2022, the UK government revealed its plans to stamp out unregulated cosmetic procedures, including botulinum toxin and fillers.
A week later, on March 7, an amendment to the Health and Care Bill was agreed upon in the House of Lords, giving the UK Secretary of State for Health and Social Care – currently Sajid Javid – the power to introduce a licencing regime for non-surgical cosmetic procedures.
The shake-up aims to ensure consistent standards across the industry and protect individuals from those without licences and the potentially harmful physical and mental impacts of poorly performed cosmetic procedures.
Many key players in the aesthetic medicine industry reacted positively to the announcement – after all, it follows years of campaigning from various groups for better regulation and patient safety.
Professor David Sines, CBE, chair and registrar of the Joint Council for Cosmetic Procedures (JCCP), said: “The JCCP was delighted to receive confirmation that the Secretary of State is now minded to introduce a national system of licensing for non-surgical cosmetic procedures in England.
“The JCCP places patient safety and public protection at the heart of all of its activities and has campaigned relentlessly over the past four years for the implementation of a nationally approved system of licensing for the aesthetic sector, underpinned by mandated standards for education and training for all practitioners.”
Currently, the details and scope of the licencing are unknown and will only be decided by the Government after “extensive engagement and public consultation.”
Reliable industry bodies are primed to participate in this process. President of the British College of Aesthetic Medicine (BCAM), Dr Uliana Gout, said: “We strongly support this move and are engaging with the DHSC (Department of Health and Social Care) to offer any further information that can help in the consultation process. BCAM is a charity focused on safety and education, so anything that helps to achieve these aims is most welcome.”
Few would disagree with the good intentions behind introducing such regulations. However, concerns have been raised about how much input the Government will actually take on board from the aesthetic medicine professionals it consults with. Plus, it is not known how long the licensing system will take to be implemented. This could be cause for future frustration, especially as the industry already has a clear idea of what is required.
Not only is a nationally accredited education and training system needed, but there are also calls for criteria concerning the hygiene and safety standards of premises and the supply and prescription of drugs. Uncertainly also abounds over what the policing of the unlicensed practitioners will look like and whether the regulations will ensure that insurance companies will exclude any practitioner from being insured that cannot meet the criteria required.
“There will also be the need to work with the CQC (Care Quality Commission) and the MHRA (Medicines and Healthcare products Regulatory Agency) to ensure there are no over-regulation or gaps in the system,” added Sharon Bennett, chair of the British Association of Cosmetic Nurses (BACN). “To put in place all that’s required will be a huge amount of work, which will take considerable time.”
PRACTICE MAKES PERFECT
Arguably most contentious of all, however, is the issue of who the licencing will be mandatory for. “Personally, I’m not holding my breath for the kind of regulation needed, and I’m apprehensive that licensing could be a considered solution,” says Emma Davis, Save Face’s clinical director. “It would be inclusive – not exclusive – of beauty therapists (APPG recommendations), and I cannot see it being fit for purpose or being implemented anytime soon, if at all.”
Emma points to the probability that the framework will only apply to medics and healthcare professionals. This would lead to a system where those already held accountable by their governing bodies would be required to follow the new laws. Meanwhile, the rules would not apply to the unregulated and untrained – the ones most likely to engage in unsafe and dangerous practices.
It’s a situation Scotland currently finds itself in. The country successfully introduced regulations for medical aesthetic practitioners in 2020 by mandating that they must be HIS (Healthcare Improvement Scotland) registered. Yet non-medics remain unregulated. England would do well to avoid this skewed, two-tier system.
“The ideal scenario,” Antonia Mariconda, founder of The Safety in Beauty Campaign, said, “would be a new regulatory body with which all aesthetic practitioners should be registered. Anybody not registered within that regulatory body would be viewed as working illegally.”
So while the Government’s plans to implement a licencing regime is a milestone achievement and the successful campaigning of the JCCP, BCAM and others must be celebrated, there is still much work to be done. To make the licencing successful, the industry is relying on the Government to take heed of its concerns, most worryingly of all, whether it will apply to the untrained ‘practitioners’ continuing to put patient safety at risk.