The British Association of Medical Aesthetic Nurses (BAMAN) has published its response to the Scottish Government’s consultation on the regulation of non-surgical cosmetic procedures.
The organisation supports the implementation of a structured licensing regime to enhance patient safety, while also calling for stronger enforcement measures and clearer classification of treatments.
Proposed regulation framework
The Scottish Government’s proposal groups procedures into three categories based on risk level:
- Group 1: Low-risk, minimally invasive procedures such as microneedling, superficial chemical peels, IPL/LED therapy and laser hair removal. BAMAN supports allowing trained non-healthcare professionals to perform these treatments in licensed premises. However, it stresses the need for private prescribing frameworks for procedures involving Prescription Only Medicines (POMs).
- Group 2: Higher-risk treatments including mesotherapy, toxin injections and medium-depth chemical peels. BAMAN advocates for these procedures to be performed only in Healthcare Improvement Scotland (HIS)-regulated settings, under the supervision of qualified healthcare professionals. The organisation also calls for greater enforcement powers to ensure compliance.
- Group 3: High-risk procedures such as platelet-rich plasma (PRP) injections, microsclerotherapy and deeper chemical peels.
BAMAN supports restricting these treatments to HIS-regulated settings and performed exclusively by qualified healthcare professionals.
Key recommendations and concerns
BAMAN has raised several concerns regarding the classification of procedures and is pushing for clearer definitions and stricter standards. Key points from its response include:
- Reclassification of certain procedures: BAMAN believes treatments involving POMs should be moved to Group 3 for increased regulatory oversight.
- Practitioner licensing and standards: The organisation supports licensing requirements for Group 1 practitioners and emphasises the need for standardised competency frameworks.
- Hygiene and safety regulations: BAMAN agrees on the necessity of hygiene and safety standards for licensed premises and supports mandatory insurance indemnity for patients affected by malpractice.
- Enforcement and inspection: Stronger enforcement powers for local authorities are a key priority, with BAMAN calling for the ability to revoke licenses from non-compliant practitioners.
- Vehicle-based procedures: BAMAN firmly opposes allowing non-surgical procedures to be performed in mobile treatment vehicles.
- Age restrictions: The organisation backs a minimum age of 18 for all non-surgical cosmetic procedures, emphasising the importance of informed consent.
Protecting public safety and reducing inequality
BAMAN believes licensing regulations will help safeguard vulnerable individuals from unregulated practitioners and unsafe treatments.
The association argues that regulation will create a fairer industry, ensuring that clinics adhering to high safety standards are not undercut by unregulated competitors.
Additionally, BAMAN highlights the importance of protecting consumers in rural and island communities, ensuring they receive safe and regulated treatment options.
The organisation also notes that the proposed regulations align with the UN Convention on the Rights of the Child, reinforcing protections for younger individuals.
Have your say
BAMAN is encouraging industry professionals and members of the public to participate in the Scottish Government’s consultation to help shape the future of non-surgical aesthetic regulations.
The association warns that under current laws, individuals without a medical background can complete a short training course and begin offering Botox and dermal fillers – sometimes in unregulated and unsafe settings such as mobile vehicles, home kitchens and hair salons.
BAMAN stresses that stronger regulations are needed to prevent botched procedures and protect patient safety.
According to Save Face, over 3,000 botched procedures were reported in the UK last year.
To contribute to the consultation, visit the link below and submit your response before the deadline. BAMAN has also prepared a PDF guide to help inform responses.
