Botulinum Toxin And Regulation

1. Facial Aesthetics and Regulation

Currently, there is no regulatory body or any formal process of regulation regarding the administration of non-surgical facial aesthetics. However this will be changing in the not too distant future – more on this later. In the meantime, there are, of course, bodies that regulate dentists (and their requirements will apply to dentists who carry out facial aesthetics).

Initially, the GDC did not see the provision of facial aesthetics services as part of the act of dentistry but this changed several years ago. Now non-surgical aesthetics comes under there remit of dentistry. Therefore, the GDC expects any practitioner to provide the same level of care and competence for this service as they would for dental treatment.

All of the GDC’s Standards need to be applied to the facial aesthetics business, namely:

• Standards for dental professionals
• Principles of patient consent
• Principles of patient confidentiality
• Principles of dental team working
• Principles of complaints handling
• Principles of raising concerns
• Principles of management responsibility
• Principles of ethical advertising.

If you are providing facial aesthetics within your dental practice, then it will come under the Care Quality Commission’s (CQC) remit. If you are providing these services away from your premises, then currently it will not. However, bear in mind that irrespective of your premises, if you are treating hyperhidrosis (excessive underarm sweating), the CQC may feel it comes under their remit. This is because hyperhidrosis is classed as a disorder that must be diagnosed before any treatment can be provided. It is further defined as such by the NHS. This makes it a ‘regulated activity’ within the CQC in England (with similar requirements in Wales, Scotland and Northern Ireland).

Looking to the future, as a result of the PIP implant scandal, Sir Bruce Keogh was asked by the Department of Health to investigate the cosmetic interventions industry. He was asked to look at:

• Standards for cosmetic surgery practice and training
• Fillers as a POM (prescription only medicine)
• Registration
• Accreditation
• Record of consent
• Advertising restrictions
• Professional indemnity cover.

The Keogh report was produced in April 2013 and the Government responded to it in February 2014. Work is underway to create documentation and, where necessary, legislation to implement a number of the key recommendations, which included:

• A register of everyone who performs surgical or non-surgical cosmetic interventions
• Classifying dermal fillers as a prescription only medical device
• Ensuring all practitioners are properly qualified for all the procedures they offer
• All non-surgical procedures must be performed under the responsibility of a clinical professional who has gained the accredited qualification to prescribe, administer and supervise aesthetic procedures
• A ban on special financial offers for surgery
• An advertising code of conduct with mandatory compliance for practitioners
• Compulsory professional indemnity in case things go wrong
• An ombudsman to oversee all private healthcare, including cosmetic procedures, to help those who have been treated poorly.

European involvement

In 2014, the new European Aesthetics Surgery regulatory standards gained CEN (European Committee for Standardisation) approval. Much of the legislation is set to crack down on the inconsistency of procedural standards, training requirements, and the condition of both surgical and non-surgical aesthetic treatment centres.

The Aesthetics Surgery Services bill is designed to provide an overall set of minimum standards and quality guidelines for any practice carrying out cosmetic and aesthetic surgery – and it will apply to any EU member states governed by CEN. This includes the United Kingdom, as well as other European countries. However, the UK has been allowed what’s known as an ‘A-deviation’ to the legislative standards. This will probably mean that there will be two separate documents published – one relevant to surgical procedures (such as face-lifts or breast augmentations), and another that applies more specifically to non-surgical procedures (like Botulinum Toxin injections).

2. Next free BTC webinar is on ‘Show me the money’ at 8.30pm Monday 27th July. To register please visit https://dentalpropertyclub.leadpages.co/webinar-show-me-the-money/

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Call 07711 731173 or email [email protected] for more information on why you should choose BTC to help you achieve a successful aesthetic business.