Information relating to evidence of harm associated with a range of non-surgical cosmetic procedures: FOI release

Information requested

Information relating to evidence of harm associated with a range of non-surgical cosmetic procedures, information on complication rates and patient outcomes, assessments of proportionality and alternative regulatory approaches, and correspondence and briefing material relating to the regulation of these procedures.

We have interpreted the numbering of your request as set out below and have responded accordingly.

"1. Any recorded evidence showing that the following procedures have caused significant harm in Scotland:

1. Advanced electrolysis
2. Thermolysis
3. Electrocautery
4. Cosmetic skin tag removal
5. Cosmetic blemish removal
6. Cosmetic skin lesion removal
7. Cryotherapy
8. Plasma treatments
9. Mesotherapy
10. Any reports, datasets, adverse event summaries, clinical reviews, incident reports, literature reviews, briefing papers, research papers or analyses relied upon when assessing the safety of each procedure listed above.
11. Any recorded evidence showing that restricting any of these procedures to HIS-regulated premisesor other medically regulated environments is expected to reduce complications, injuries or adverse outcomes.
12. Any recorded evidence comparing complication rates, adverse event rates, serious incidents orpatient outcomes between the following practitioner groups: a. Independent aesthetic practitioners
13. Beauty therapists
14. Nurses
15. Doctors
16. Dentists
17. Dermatologists
18. Pharmacists
19. Other practitioner groups

5. Any recorded information identifying, separately for each procedure listed at paragraph 1, the number of:

1. Reported complications
2. Serious injuries
3. Hospital admissions
4. Permanent injuries
5. Deathsattributed to that procedure in Scotland.
6. For any figures supplied under paragraph 5, please provide any recorded information showing: a.The period covered

1. The source of the information
2. Whether the incident was independently verified
3. The professional or practitioner category involved
4. The approximate number of procedures undertaken during the same period, where denominatordata is held

7. Any recorded information distinguishing complications attributed to practitioner competence from those attributed to: 

1. Product failure or contamination
2. Patient-specific factors
3. Underlying medical conditions
4. Equipment failure
5. Failure to follow aftercare instructions
6. An expected or recognised treatment risk
7. Other causes
8. Any recorded evidence, assessment or analysis showing that existing local authority licensing, environmental health regulation, professional standards, training requirements, insurance requirements or other less restrictive regulatory measures were considered insufficient to address the identified risks.
9. Any recorded assessment demonstrating that the proposed restrictions are proportionate to the level of risk associated with each individual procedure.
10. Any recorded consideration of less restrictive alternatives, including:
11. Procedure-specific licensing
12. Minimum training and qualification requirements
13. Grandparenting or recognition of prior experience
14. Inspection of independent premises
15. Mandatory insurance
16. Complication reporting requirements
17. Infection prevention and control standards
18. Equipment standards
19. Practitioner registers or accreditation arrangements.

11. Any correspondence, briefing papers, meeting notes, presentations, reports or other recorded communications exchanged between the Scottish Government and any of the following concerning evidence of harm, complication rates, patient safety or the proportionality of restricting these procedures:

1. Healthcare Improvement Scotland
2. Joint Council for Cosmetic Practitioners
3. British Association of Medical Aesthetic Nurses
4. Save Face
5. Scottish Medical Aesthetics Safety Group
6. British College of Aesthetic Medicine
7. Insurers or insurance intermediaries
8. Academic institutions
9. Local authorities
10. Any other stakeholder consulted on these matter

Response

We have provided electronically copies of the information falling within the scope of your request that we are able to release. Full details of the information identified, together with any exemptions applied, are set out in the attached Exemption Annex.

Question 1 (and Questions 2 to 11, which relate to the treatments identified in Question 1);

We have identified 18 documents falling within the scope of your request.

Documents 2, 6, 8, 17 and 18 are duplicates of other records and have therefore not been considered separately as part of this response.

We are releasing copies of the information that falls within the scope of your request and can be disclosed. The information being released accompanies this letter.

While our aim is to provide information whenever possible, some information has been withheld because exemptions under the Freedom of Information (Scotland) Act 2002 (FOISA)apply. Details of the exemptions applied and the reasons for their application are set out in the attached Exemption Annex.

Information already publicly available

Document 1 is publicly available as part of FOI response 202600510956 (page 23) and Document 15 is publicly available within the Supplementary Delegated Powers Memorandum accessible for the Nonsurgical Procedures and Functions of Medical Reviewers (Scotland) Bill.

Under section 25(1) of FOISA (Information otherwise accessible), we do not have to provide information which is already reasonably accessible to you.

If you do not have internet access, please contact me and I will arrange for paper copies to be provided.

Information withheld

The following documents have been withheld in full under section 30(b)(i) of FOISA (Free and frank provision of advice):

• Document 5
• Document 7
• Document 9

In addition, parts of Document 5 have been withheld under section 30(c) of FOISA (Prejudice to the effective conduct of public affairs).

Document 10,11,12 and 14 have been withheld in full under sections 36(1) (Confidentiality in legal proceedings) and 30(b)(i) (Free and frank provision of advice) of FOISA. Certain information within this document also falls outwith the scope of your request and has therefore not been considered.

The following documents are being released with redactions:

• Document 3: sections 30(b)(i), 30(c) and 38(1)(b)
• Document 4: sections 30(b)(i), 30(c) and 38(1)(b)
• Document 13: sections 30(b)(i) and 38(1)(b)
• Document 14: section 30(b)(i) and 38(1)(b)
• Document 16: sections 30(b)(i) and 38(1)(b)

Further details of the exemptions applied, together with explanations of why they apply, are provided in the attached Exemption Annex.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

FOI 202600525751 - Information released - Annex A

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PDF

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158.6 kB

FOI 202600525751 - Information released - Annex B

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238.8 kB