5 mins
A STEP FORWARD?
Last month, the Government rejected urgent calls for a licensing regime to regulate non-surgical cosmetic procedures. Dr Sophie Shotter and Dr David Eccleston give their thoughts on the government’s response
AM: What are your first thoughts on the latest response from the Department of Health and Social Care (DHSC)?
Dr Eccleston: The whole aesthetics industry is in a strange place at the moment, with considerable growth in the number of providers – both those who are unregulated, as well as healthcare professionals that are regulated by a professional body and associated codes of practice. Given that the horse has probably bolted, we now need to set out common standards, minimum education requirements and basic principles for managing safe premises – good hygiene, patient care, adverse event management as well as record keeping. The new law in England that will require a licence for the premises where non-surgical cosmetic procedures take place is a good move but does not license the practitioner who holds the syringe.
Dr Shotter: As a British College of Aesthetic Medicine (BCAM) trustee, I am well-informed about what’s been going on in the drive for regulation, and I’m excited to see the progress. However, it’s slower than I think all of us would like. I believe we are looking at July 2025 before we have regulation in place. One of the most controversial conversations has been around whether fillers should be made prescription-only, and I understand that is not looking likely. I’m not as upset about that as some people may imagine, as making botulinum toxin prescription only hasn’t stopped people who shouldn’t be injecting it from being able to inject. I believe we need a strong ethical framework around remote prescribing which is enforceable by regulating bodies to help control this before we try to insist on making fillers prescription-only devices.
AM: Which aspect of the announcement are you most interested in?
Dr Shotter: I think the conversation around the regulation of premises and the fact that there could be an appetite to form a regulatory framework involving the CQC is exciting. This would make it very difficult for lay people to inject, as the CQC’s requirements are very strict and require medical oversight. The part that still worries me a little is that the current proposed framework wouldn’t be able to stop allied health professionals from injecting unless their regulatory bodies say it’s outside of their scope of practice. For example, podiatrists who have enormous expertise in the anatomy, physiology and pathology of feet have, in my opinion, no place injecting faces. But unless their regulator states that facial aesthetics is outside their scope of practice (which has happened with physiotherapists) it may be very difficult to control. I don’t understand where this desire to be a jack of all trades comes from – be proud of your area of expertise, but don’t pretend that confers all-over expertise that you don’t have.
Dr Eccleston: Put simply, injection of any product under the skin, whether it be a muscle-relaxing injection or a dermal filler, requires detailed knowledge of anatomy, physiology and pharmacology, and the ability to manage an emergency adverse event that may subsequently arise as a result of such treatment. By definition, such emergency treatment will require the treating practitioner to administer prescription-only medication, which cannot, by law, be done by a non-medically trained individual. Whereas, doubtless there are many skilled non-medical injectors out there, and contrarily, some medical injectors with a poor skillset, the fact remains that without medical training, non-medical injectors are simply not in a position to safely exclude disease, assess mental health, understand contraindications, and manage potentially life-threatening complications.
Dr Shotter: What I do know is that the standards that practitioners will have to meet for the JCCP register are not going to be easy to prove, even for a doctor. We have to remember that competency isn’t just a medical, dental or nursing degree and the proof of training, experience and commitment to ongoing development will be essential to prove.
AM: What areas do you think need more attention?
Dr Shotter: Working collaboratively with BCAM I am keen to make sure that the standard of a medical qualification is appreciated and considered. It shouldn’t be the case that practitioners who’ve been practising aesthetics and medicine for several years must go back to square one on everything. Regarding regulation, the problem is we are now trying to get the horse back in the stable after it’s bolted and that makes everything more complicated!
Dr Eccleston: While I welcome this move to professionalise the entire sector, I am worried that one of the main views expressed by the DHSC seems to be ‘consumer beware’. If that is going to be a guiding principle for the dynamic and ever-changing sector of non-surgical cosmetic procedures, then those of us who have extensive qualifications, broad expertise, and uphold the standards will need to get better at making it clear why these are important to our clinical practice.
AM: Where do you hope to see the aesthetics industry a year from now?
Dr Shotter: We should be moving towards making aesthetics a medical specialty rather than an industry. Injectables should be performed by specialist doctors, dentists, and prescribing nurses who have proven appropriate standards of competency and experience. These professionals will work collaboratively with others as part of multi-disciplinary teams to ensure the best care and results for their patients. This is the model we follow within mainstream medicine, and it is how we should be working within aesthetics. You work in a team that incorporates all these other people and skill sets, including beauty therapists, without whom my businesses wouldn’t function. But we all work within our remits that are appropriate to our qualifications, skill sets and competencies.
DR SOPHIE SHOTTER
Dr Sophie Shotter is a cosmetic skin doctor and renowned injector. She sits on the complications board for Allergan and most recently joined the British College of Aesthetic Medicine (BCAM) board. Dr Shotter is the founder and medical director of the Illuminate Skin Clinic in Kent. Currently, she splits her time between there and her private practice on London’s Harley Street.
DR DAVID ECCLESTON
Dr David Eccleston is a cosmetic doctor and GP with a special interest in dermatology, based in Birmingham. He is the clinical director of MediZen, a multi award winning clinic in Sutton Coldfield and is highly experienced in the treatment of hyperhidrosis using toxin injections and the miraDry system.