Public health bodies welcome parliamentary report recommending better regulation of cosmetic treatments

21 July 2021, Tamara Sandoul

A coalition of public health bodies and professional registers have strongly welcomed the flagship report from the All-Party Parliamentary Group (APPG) on Beauty, Aesthetics and Wellbeing. The APPG report concludes its long inquiry into non-surgical cosmetic procedures, recommending a national licensing regime to be introduced across England and some minimum qualification standards to be set for practitioners carrying out the treatments.

CIEH, Institute of Licensing (IoL), UK Public Health Network (UKPHN), The Joint Council for Cosmetics Practitioners (JCCP), Save Face, and the Royal Society for Public Health (RSPH) have come together to support these key recommendations in the report and call on the Health Minister, Nadine Dorries MP, to take these recommendations on board in a timely manner to protect the public and promote patient safety.

The coalition of public health bodies came together in May to a write joint letter to  the Minister, calling for better regulation of cosmetics treatments. The letter outlined three essential changes to make cosmetic treatments safer for the general public; the creation of a national licensing scheme, official guidance developed for the implementation of standardised mandatory training and qualification requirements, and better recording of adverse events.

CIEH and IoL have also found overwhelming support for the introduction of an England-wide licensing scheme rather than registration in their report The ugly side of beauty: improving the safety of cosmetic treatments in England, where 90% of regulators agreed that a licensing scheme could improve the regulatory system and protect the public from harm. The JCCP has also identified significant support for the design and implementation of such a national licensing scheme and has outlined the Council’s proposal as part of its published Ten Point Plan for Safer Regulation in the Aesthetic Sector.

The regulation of cosmetic treatments varies across the UK. In England and Northern Ireland, cosmetic premises only need to register with the local authority but there are no powers to refuse registration. In Wales, a national licensing scheme is currently being implemented but only for five treatments, excluding some presenting higher risk procedures such as botulinum toxins and dermal fillers. In Scotland, a government consultation last year sought views on introducing a licensing regime for cosmetic treatments.

The APPG inquiry and report has been vital in helping to raise awareness of cosmetic treatments and the potential risks involved for members of the public. In RSPH’s report Skins and needles, it was found that two thirds of members of the public had not checked whether the technician/practitioner was registered with their local councils.

However, whilst containing a range of laudable recommendations the APPG report falls short of calling for sufficient qualification and competence requirements for practitioners who administer some of the more risky and potentially harmful procedures, such as the insertion of dermal fillers of the injection of toxins (e.g. Botox). In the joint letter sent to the Minister in May, the public health bodies and practitioner registers called for injectables and fillers only to be administered by certain designated and appropriately trained healthcare professionals, who have the necessary skills, qualifications and competence in these areas.

Furthermore, the APPG inquiry only focussed on the riskiest cosmetic procedures such as dermal fillers and injectables. A whole raft of other cosmetic treatments are also poorly regulated in England and Northern Ireland, where old legislation and a registration system is used rather than licensing schemes, where practitioners would need to prove they are competent in order to practice.

Dr Phil James, CIEH Chief Executive, said:

“There is much to be welcomed in this report. The inquiry has delved deep into the cosmetic industry from insurance to standards and qualifications.

This is a great step forward in realising the complexities of the growing cosmetic industry and creating public protections. Our flagship reports and those of the other organisations we work with have shown that action must be taken. It is vital that the most invasive procedures are undertaken by qualified, licensed and experienced healthcare professionals.

Unfortunately, the legislation that local authorities rely on to regulate this sector is now very out of date and something new and effective is needed to support regulators in protecting members of the public.

The APPG inquiry has always focussed on the most risky beauty treatments but all cosmetic procedures currently regulated via registration schemes need to move over into a comprehensive licensing  regime going forward, so that the public can be confident that all treatments offered on the high street or at their home are safe.”

Daniel Davies, IoL Chairman, said:

“The IoL welcomes the report from the APPG on Beauty, Aesthetics and Wellbeing. The inquiry into the industry has been timely, and has highlighted the inadequate regulatory regime which has challenged the regulators for many years. The nature of the industry changes with the times, as new treatments and techniques emerge, but the legal landscape is significantly outdated, and there is extensive scope for improvement.  The Report has picked up on many important issues and, whilst there is much more work to be done, this represents crucial acknowledgment and understanding of the clear need for reform.”

Professor David Sines CBE Chair of The Joint Council for Cosmetic Practitioners (The JCCP), said:

“The JCCP places public safety and informed consent at the heart of its mission. It considers that further understanding of the benefits and risks associated with aesthetics sector is required and this should be delivered by qualified and trained practitioners that use the correct equipment underpinned by evidence-based practice.

The JCCP is pleased that some of the recommendations in the Report complement key recommendations from its Ten Point Plan for Safer Regulation in the Aesthetics Sector, but this does not go far enough. The report emphasises the current inadequacy of primary and secondary legislation to enable LAs in England to enforce the standards and enforcement required to protect the public but the Government now needs to enact a new system of oversight, scrutiny and governance to give LAs and HSE additional health and safety powers to take action against malpractice.

The JCCP believes there must be nationally endorsed and enforceable mandatory education and training standards for all practitioners in sector. The use of more invasive aesthetic treatments, such as injectables, fillers, ‘deep peels’ etc. should only be performed by designated registered health care professionals who have been appropriately trained and are experienced in their administration. Voluntary registration can only provide limited public protection as practitioners who are not required to follow nationally prescribed standards can still practise legally, leaving members of the public at risk.”

Christina Marriott, Chief Executive, Royal Society for Public Health, said:

“Nearly one in five members of the public experienced a negative effective following a non-surgical treatment. Infection control qualification, such as the RSPH Level 2 Award in Infection Prevention and Control, must be an essential component of cosmetic licensing. Last year, Wales introduced infection prevention qualification as part of a mandatory licensing scheme. It is time that England follows suit.”

Nicola Close, Chief Executive of ADPH, representing the UKPHN Executive Group, said:

“The UK Public Health Network welcomes the publication of the BAW APPG report and the spotlight it shines on aesthetic non-surgical cosmetic treatments. Particularly encouraging in the report is the call for effective legislation to better regulate the sector and protect the public’s health.

Alongside a licensing regime to promote consistent regulation across the sector, the UK Public Health Network advocates alongside its partner organisations for a robust training and competence framework which ensures that non-surgical cosmetic procedures are carried out by qualified healthcare professionals in safe environments.”

Ashton Collins, Director of Save Face, said:

“Improving public safety is intrinsically embedded within our accreditation model and we support any measures that will deliver a safer landscape for members of the public who undergo non-surgical cosmetic interventions. However, we do not feel that some of the recommendations outlined within this report go far enough to tackle the underlying issues that lead to so many people to fall into unsafe hands. Our accreditation standards are robust and exceed those required by the Professional Standards Authority because we recognise the increased level of risks that exist within this marketplace. Therefore, we cannot endorse any scheme that is ‘inclusive for all providers’ because a one size fits all approach will not deliver the safety measures required to ensure that the breadth of different providers who operate within this field are competent and safe to practice.

We welcome the opportunity to contribute to the wider development on a National Standard for Education and Training. Earlier this year Save Face launched the Qualification Council For Cosmetic Procedures (QCCP) to develop an accessible and affordable route to gain regulated qualifications in Botulinum Toxin and Dermal Filler treatments. All QCCP qualifications are regulated and awarded by The Royal Society For Public Health.”

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