Scottish Cosmetic Interventions Expert Group minutes: May 2025

Attendees and apologies

• Andy Malyon (AM) (Scottish Government (SG) and NHS GG&C) – Chair
• Lesley Blair MBE (LB) (BABTAC and CIBTAC)
• Sara Davies (SD) (SG)
• John Elder (JE) (BCAM)
• Kevin Freeman-Ferguson (KFF) (Healthcare Improvement Scotland)
• Martin Gibb (MG) (Glasgow City Council)
• Tom Gorman (TG) (Glasgow City Council)
• Anne Macleod (AMac) (South Lanarkshire Council)
• Alun Parry (AP) (SG)
• Jackie Partridge (JP) (Dermal Clinic & British Association of Medical Aesthetic Nurses (BAMAN)
• Julie Wales (JW) (Glasgow Clyde College)

Apologies

• Elaine Hutton (EH)

Items and actions

Welcome and introductions

AM welcomed everyone to the first meeting of 2025.

Previous Action Points

The minutes from the October meeting had been agreed by email following that meeting and have been published. 

JP highlighted that minutes sent with the agenda contained some minor tracked changes. SG will resend the final version.

Previous action points have been cleared.

Action Point
SG to resend the final version of October 2024 minutes.

Consultation – process, update and next steps

An update on the consultation process and next steps was given:
•    The consultation was launched in December 2024 and closed on 14 February 2025
•    SG will respond to the consultation analysis before parliamentary recess (end of June)
•    SG response will set out next steps following engagement feedback and consultation responses
•    SG has benefited from discussions and advice from SCIEG
•    All views are important and are being considered
•    SG has run targeted engagement to reach those who had not been heard and those who would be most strongly affected by the proposals.  
•    SG needs to build evidence base of any impact, which will need to be proportionate, and prepare Impact Assessments. JH later added that SG must get balanced views from all stakeholders and is legally required to undertake impact assessments. SD confirmed that advice SG gives to ministers draws on the available evidence. OG added that regulation will need to be proportionate and consider UNHRC or it will be subject to challenge.
•    Advice will go to the minister for her to make decisions. SG cannot pre-empt decisions in advance of them being made by ministers
•    The Programme for Government (PfG), which includes Bills that will be taken forward by the government prior to parliamentary elections next year, is being announced this afternoon. The link will be shared once PfG announced. 
•    Ministers’ decision and next steps in regards to regulation is subject to parliamentary processes.

SG confirmed that they had benefited from the views, concerns and advice of healthcare professionals and had to also consider people who had not been heard from, including those whose businesses would be impacted by the proposals. SG held 2 engagement events for non-healthcare practitioners – one in person and one online

LB was disappointed not to have been invited to the non-healthcare practitioner engagement events and asked if she could be invited to future events.

Consultation - feedback

SG received over 2200 responses to the consultation, which was more than for the previous consultation and proportionately more than the UK Government consultation.

There was a broad range of respondents, some from large organisations. Half of respondents were from the NSCP sector while the other half was not connected to it.

In addition to the responses, SG has met with stakeholders, run engagement events and received correspondence as further evidence.

There were a range of views about the grouping coming out of the consultation and that AM and SD had also provided further advice as have other SG policy colleagues e.g. Medicines and Professional Regulations teams.

LB said that we need non-healthcare aesthetic practitioner views. She supports what they are saying however any decisions need to be on safety grounds and not for commercial interests. The same standards, oversight and restrictions must apply across the board.

JE raised concerns from medical colleagues that business implications should be secondary to safety and concerns that current legislation, e.g. medicines etc, are being breached. AM, supported by SD, agreed and pointed out that MHRA takes action in regards to medicines where it can and that SG cannot affect its resourcing to enforce regulations.

TG advised that MHRA had contacted Glasgow EHOs to ask if they could be involved in a campaign regarding fake products, e.g. skinny jabs such as Mounjaro. JP is of the view that General Pharmaceutical Council guidance should stop this.

JP also highlighted the new NMC guidance on face-to-face prescribing of prescription-only medicines for cosmetics which come into effect on 1 June. She added that the NMC will also look into weight loss jabs. JP feels that ‘oversight’ should be limited to one-to-one so that it is safe and appropriate.

AOB

MG asked about what work is being undertaken to determine competency benchmarks for procedures (e.g. lasers). OG advised that this would be addressed later.

JP said that previous discussions included proposals requiring a Level 7 in NSCPs for healthcare professional. She said that a pathway is required going forward.

Officials confirmed that proposals will require both primary and secondary legislation.

AM thanked members for their contribution to the group. He confirmed there was no plan for future meetings of the whole group at this stage but that there may be a call for subgroups to consider specific topics. The group was content with this.

List of Action Points

1. SG to resend the final version of October 2024 minutes.