Nearly all GPs will have patients who have had non-surgical procedures and some GPs are already practising aesthetics, or are contemplating working in the field.
Later this month, on 22 February, new regulations concerning non–surgical aesthetics will be launched in the House of Lords. The industry has grown quickly and many minimally trained practitioners are delivering treatment. Botulinum toxin as a prescription medicine is regulated by law, but beyond that there is little regulation. Legally anyone can inject anyone else, meaning any beautician or even plumber can obtain dermal filler and inject a patient, with no training.
The Keogh Report, published in 2013 in the wake of the PIP (Poly Implant Prostheses) breast implant scandal, suggested tighter regulation of non-surgical aesthetic procedures. Many of us called for legislation prohibiting non-clinicians from injecting patients for cosmetic purposes. It is disappointing that this has never been implemented by Government. After some lobbying, we understand the Government intends to make dermal fillers prescription-only from 2020.
In response to Keogh, the Government asked Health Education England (HEE) to develop a framework for the whole industry covering procedures from microneedling and light peels, to laser and injectable treatments. The scope covered beauty therapists to medically qualified individuals.
It will be very difficult for non-clinicians to be able to reach the standards required
The HEE report outlined levels of competence. Each level stated what procedures could be undertaken and level of training required. Level 7 is minimal safe independent practice. This required a post-graduate knowledge level and practical training plus observed practice of the procedures.
On the basis of the HEE recommendations the Department of Health wished to develop a regulatory framework. The British College of Aesthetic Medicine (BCAM) representing doctors and dentists, and the British Association of Cosmetic Nurses (BACN) agreed to start work on this. Separately three other bodies, BAD (British Association of Dermatologists), BAAPS (British Association of Aesthetic Surgeons) and BAPRAS (British Association of Plastic, Reconstructive and Aesthetic Surgeons), were also keen to work on standards. The five organisations agreed to work together.
Two new independent bodies will work conjointly to enforce the regulations from March. The JCCP (Joint Council for Cosmetic Practitioners) will oversee registers of practitioners and training organisations, police standards and report to professional organisations such as GMC. The CPSA (Cosmetic Practitioner’s Standards Authority) will set standards for the various levels of competence of practitioners and training organisations.
There will be a framework of standards for practitioners and training organisations, two registers for practitioners, one for clinicians and one for non-clinicians, plus a register for training organisations.
In practice, it will be very difficult for non-clinicians to be able to reach the standards required for independent practice. The professional organisation’s view is that non-clinicians should not be injecting patients. All clinical professionals performing the occasional treatment will still have to reach the required standard so may decide it is not worth pursuing. The GMC and other professional bodies are supportive of the JCCP and will work them to ensure standards of practice are interchangeable. Of course, there is no ‘body’ to prevent non-professionals working as they are not answerable to a particular professional organisation. The register may encourage unregistered practitioners to go ‘underground’ and without legislation they cannot be stopped. Hopefully public awareness about safety and increasing difficulties in obtaining supplies may make it difficult for these people. Trading standards and the possibility of civil action for assault if someone falsely claims that they are a clinician may also help to discourage them.
What does this mean for GPs who wish to start in aesthetics? BCAM has launched the BCAM Academy, which will provide support and guidance to GPs wishing to embark on training in this field, and already work with training organisations. New entrants can work towards attaining the skills required for independent practice. BCAM is developing a membership examination which will hopefully become a credentialed specialist qualification.
For GPs generally, awareness of the regulations will allow them to advise patients on how to make a more informed choice about who to go to for treatment. Hopefully, we will all see less complications.
It is a start, but more needs to be done to make the industry safer.
Dr Paul Charlson is a GP, aesthetic doctor and president of the British College of Aesthetic Medicine
This article was amended on 20 February 2018 to clarify that it is the BCAM’s understanding that the Government intends to make dermal fillers prescription only, although this is not confirmed
