CQC and JCCP host joint roundtable

The JCCP and the CQC jointly hosted a meeting of representatives from a range of organisations to explore and consider what is currently happening in the area of lifestyle choices and cosmetic interventions and to consider and share ‘concerns on the ground’ relating to public protection and the current ‘regulatory framework’ that exists for this purpose. 

The organisations represented at the event were: The Advertising Standards Authority; CQC; CPSA; MHRA; Public Health England; Chartered Society for Environmental Health; GDC; GMC; GPhC; HCPC;  Independent Doctors Federation Regulation Committee and NMC. 

The Key aims of the event were confirmed as being: 

‘To consider whether the current regulatory framework for cosmetic special treatments (including hair restoration surgery) and lifestyle therapies provides sufficient protection to safeguard the public from undue harm or consequence and to identify existing gaps in regulatory practice and legislation’. 

Key Messages 

Representatives affirmed that a number of ‘more invasive’ cosmetic interventions and so-called lifestyle therapies raise significant challenges for regulation especially in terms of current definitions of ‘treatment and disorder’. It was agreed that: 

• • There is the potential for significant risk to be posed to the health and wellbeing of members of the public. 
• • That there is a need for regulation to shift its focus on the potential risk of harm that some interventions can and do have to public/patient safety and to review whether adequate safeguards currently exist to minimize the effects of harm occurring with regard to certain procedural interventions performed within these sectors. 
• • That it is fundamental that cosmetic treatment and life style practitioners should possess the right knowledge and skills, safely use the right products, devices and medicines, which should be administered only in ‘safe’ premises and that members of the public should receive accurate information before deciding to undergo a cosmetic intervention or life style therapy. 

Proposed Actions and Outcomes 

The group agreed the following key priorities as a means to inform further discussion, deliberation and action: 

• The need to agree upon what constitutes ‘less invasive’ interventions that cause minimal harm and which do not require regulation. 
• The need and ‘collective appetite’ to share intelligence, data, case studies and information between regulators in order to enhance opportunities for greater public awareness, protection, service effectiveness and productivity. 
• The need to exploit opportunities to share information and advice by sharing websites and to create ‘signposting’ links between regulatory organizations with the aim of providing a more coherent corporate ‘learning platform’ and greater accessibility for members of the public to inform choice and to advise of the risks involved in some of the more invasive procedures. 
• To ‘map’ individual regulator responsibilities within these two sectors to inform and provide greater congruence and mutual understanding. 
• To explore whether renewed emphasis on public protection, safety and risk could be considered within the sector by working with Insurance Underwriters and the Insurance Regulator. 
• To consider lessons learned from Scotland with regard to the regulation of premises and to determine how similar (or adapted) models of premises regulation could be implemented in England. 
• To consider whether the current ‘Scope of Practice’ set down by the Professional Statutory Regulators provides adequate clarity with regard to public and professional expectations in these applied areas of practice (with particular regard for the more invasive treatments that have been associated with ‘harm’). 
• To consider the introduction of an agreed standards document across the five key professional practitioner statutory regulators to set out requirements for safe and effective prescribing in the cosmetics sector (as described in the CPSA/JCCP Code of Practice document). 
• To consider further the role that Public Health England and the Royal Society of Public Health might play in raising public awareness and assisting to promote greater public protection with regard to those interventions that are considered to be associated with greater risk of harm to members of the public. 
• To work closely with the Advertising Standards Authority to identify potentially misleading or inaccurate advertising claims relating to the provision of cosmetic or lifestyle treatments/interventions, the inappropriate use of products and the advertising of those practitioner training programmes that falsely claim to meet a nationally agreed standard to affirm practice proficiency. 
• To encourage further work between the Chartered Institute of Environmental Health and Environmental Health Officers and the CQC to consider what constitutes a ‘Special Treatment’ for those more invasive procedures, such as the injection of toxins and the insertion of dermal fillers, and by so doing enabling regulators to extend their ‘public duty of care’ to such treatments/procedures.
• To continue to work with the MHRA and the DHSC to further clarify the intention to regulate the supply of dermal fillers and to consider how best to protect the public with regard to the administration of the same. 

Professor David Sines – Executive Chair – JCCP said, ‘I am most grateful to the CQC for facilitating this important roundtable event with the JCCP to bring together so many of the key regulators together to discuss the critical issue of regulation in the cosmetic and hair restoration sector. These issues have been the subject of discussion for a number of years and its importance has recently been elevated by direct questions raised with the Prime Minister and by parliamentary debate. By hosting this conversation between so many parties the JCCP and the CQC believe that a more coordinated approach can be developed in the interests of public protection and patient safety. I look forward to engaging in further meetings with key interested parties and the announcement of further actions moving forward’.