Non-surgical cosmetic procedures regulation: consultation analysis - final report

Independent analysis of the responses to our consultation on the regulation of non-surgical cosmetic procedures, which ran in 2020.

Chapter 3: Conclusions

3.1 Broadly, the view from respondents was that regulation of non-surgical cosmetic procedures would be welcomed.

3.2 Most respondents felt that these procedures carried a high risk of potential physical or mental harm and should only be conducted by highly skilled professionals. Many respondents felt that only professionals who are able to both deliver the procedure andmanage any complications should be able to offer them. They felt that regulation would ensure only these professionals were able to practise non-surgical cosmetic procedures.

3.3 There were mixed views around the level of qualification and training required to be considered appropriate to deliver these procedures. Many respondents felt that only healthcare professionals with clinical training and expertise, such as doctors and nurses, would be able to achieve the standards required to operate safely. However, some respondents felt that other healthcare professionals, who are regulated by a medical council (such as pharmacists) or other individuals should be able to perform these procedures, provided they met the criteria.

3.4 Most respondents felt strongly that all people offering non-surgical cosmetic procedures should be regulated in the same way. The current regulation of healthcare professionals while others are not regulated was deemed to be unfair for professionals, and unsafe and confusing for the general public.

3.5 Although licensing as a form of regulation was welcomed by some, many respondents felt that licensing under Part 1 of the Civic Government (Scotland) Act 1982 was not adequate.

3.6 Many respondents expressed the view that standards for accountability and regulations should be the same for healthcare professionals and individuals with no health qualifications offering these procedures. They also felt that the standards should be high, given the potential complications associated with these procedures.

3.7 The requirements suggested by respondents included mandatory training, a minimum level of recognised qualification, an accreditation scheme and a national register of regulated practitioners or practices.

3.8 As well as demonstrating competence in procedures and management of complications, many respondents noted that regulated practitioners should be able to demonstrate competency in infection control, aftercare and professional ethics.

3.9 As part of the licensing or regulation, many respondents felt strongly that practitioners should be required to hold appropriate indemnity or insurance, to a level that would protect patients in the event of complications.

3.10 With regards to prescribing, some respondents felt that the products used in non-surgical cosmetic procedures should be prescription-only medicines. And some respondents called for an end to remote prescribing practices. They felt that this increased the risk of prescribers providing prescription-only medications to people who may be unable to safely administer them.

3.11 Some respondents noted that the level of rigour and regulation may preclude some people who are currently able to offer these procedures from continuing to do so.

3.12 Finally, respondents felt that there was a need for greater public awareness of the risks and complications associated with these procedures. Several called for more information or awareness raising campaigns to ensure that the general public is better informed of the risks and options available.



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