In the last three years, the number of official complaints regarding botched non-surgical cosmetic procedures such as Botox and dermal fillers has more than doubled. From 2017-18 there were 939 official complaints about cosmetic treatments, 224 of which were for problems with Botox (botulinum toxin) injections.
The rise in complaints is not because the product is unsafe. Botox has been approved by many regulatory agencies such as the Medicines and Healthcare products Regulatory Agency (MHRA). Instead, 83% of the complaints relate to the fact that treatments have been carried out by non-medical practitioners. As a result, there is a growing demand for regulations to be put in place to prevent non-medical practitioners from carrying out aesthetic treatments.
What regulations does Botox have?
The product containing botulinum toxin type A, such as brands like Botox and Azzalure, is a prescription only medicine. As a result, only a trained healthcare professional should prescribe the medication. As a result, the regulations currently stipulate that the prescriber of the medicine is responsible for ensuring it is administered safely. However, the prescriber can delegate the administration of the medicine/treatment to someone else.
It is also possible for practitioners to acquire the medicine without a prescription, mainly through online distributors. However, the quality of the product may be substandard, and sadly, the patient will be the one at risk.
Government actions for Botox regulations
As a response to the rise in cosmetic treatment complaints and the fact that 47% of remedial work is needed for fixing botched treatments administered by non-medical professionals, the government launched a review in order to put proper regulations in place.
The government asked Health Education England (HEE) to develop a review of the framework for all aesthetic treatments, from facial peels to injectables. HEE recommended following the OFQUAL regulated levels of competence. With a Level 7 Certificate being the minimum level of certification for a practitioner offering safe, independent practice.
To achieve the Level 7 Certification, the practitioner must have a post-graduate level of knowledge, conduct regular practical training and pass practical examinations and produce a portfolio of evidence.
However, Level 7 Certification is not and will not be mandatory. Level 7 Certification is not a government regulation.
After the review by HEE, the Department of Health then called for a proper regulatory framework. This was supported by several organisations who want to improve standards and agreed to work together. The bodies were;
- The British College of Aesthetic Medicine (BCAM)
- British Association of Cosmetic Nurses (BACN )
- British Association of Dermatologists (BAD)
- British Association of Aesthetic Surgeons (BAAPS)
- British Association of Plastic, Reconstructive and Aesthetic Surgeons (BAPRAS).
Following this, two independent bodies have been working together since March to enforce their regulations. This includes the Joint Council for Cosmetic Practitioners and the Cosmetic Practitioner’s Standards Authority.
The problem with Botox regulations
The problem with this, however, is that there is no ‘organisational body’ that can prevent non-professionals working. This is because they are not medically qualified and therefore, are not answerable to a regulatory body.
Furthermore, the regulations do not stop unregistered practitioners but instead, push unregistered practitioners to go further underground. Struck off medical professionals, and unregulated online markets can make obtaining supplies easy. Without legislation, they cannot be stopped.
The government response
Despite the growing concerns for botched cosmetic treatment by non-medical professionals, the government has failed to sufficiently respond to any of the recommendations put forward and set. They have not made the Level 7 Certificate mandatory.
In some cases, the government may argue that they should not have to waste valuable funds on setting up a register that is, essentially, for elective, commercial cosmetic procedures. Furthermore, this could take away much-needed funds for the NHS, which is in dire need of funding to help patients with non-elective, necessary procedures.
Regulations in Scotland
Scotland has taken a harder stance to tackle botched treatments. As of April 2017, all clinics that provide non-surgical treatment independently must register with Health Improvement Scotland. Furthermore, the clinics must pay a fee of £1990 alongside abiding by the strict requirements of registration.
What next for Botox regulations?
Until formal regulation comes into force, we recommend following the Save Face Standards for Accreditation, which offers several routes that allow practitioners to join the register. Save Face recommended three qualification routes such as the Save Face Essential Training Curriculum, the Level 7 Certification and the Professional Non-Surgical Aesthetic Practice.
As a result, the Save Face practitioner finder will only connect individuals with practitioners who have been trained and qualified and are certified medical professionals.
At Dr Hennessy Cosmetic Academy, we actively support the introduction of tighter regulations to ensure only medical professionals can administer cosmetic treatments. This is why we only train medically, qualified individuals. However, we believe the regulations need to be more encompassing than simply following one qualification route and ensure that there is scope for non-medical professionals to be held accountable.