A walkthrough of the government consultation

On September 2, the Government announced the first consultation for the licensing of non-surgical aesthetic procedures in England.

The consultation is for aesthetic practitioners and members of the public to have their say on how aesthetic procedures should be regulated. But what is being proposed, and what questions are they asking?

The three main aims of the consultation are to establish:

1. The types of treatment and procedures that should be classified as non-surgical cosmetic treatments and included in the licensing scheme.
2. Whether any procedures should only be carried out by regulated healthcare professionals or under their clinical oversight.
3. The views of the public on imposing age restrictions for aesthetic procedures.

This licensing will not cover surgical or dental procedures, as surgeons and dentists should already be registered with the General Medical Council or General Dental Council, which oversee these procedures and can offer sanctions for improper treatment.

The current plan for licensing is to use a traffic light system. Green procedures that present the lowest risk of complications could be performed by all practitioners who meet agreed standards. The green category currently proposes to include:

• Microneedling
• Mesotherapy
• Intense Pulsed Light and Light Emitting Diode therapies
• Chemical Peels that involve destruction only into viable epidermis
• ‘No-needle fillers’ including pneumatic devices that use intense pressure to pass substances through the epidermis
• Micropigmentation, including microblading and nanoblading
• Non-ablative laser hair removal
• Photo rejuvenation.

Amber procedures that present with a medium risk of complications could be carried out by medical professionals or a practitioner that meets agreed standards, under the supervision of a medical professional who holds the qualifications to prescribe, administer, and supervise aesthetic procedures. Proposed treatments for the amber category include:

• Botulinum toxin injections
• Semi-permanent dermal fillers are injected into the face only
• Biorevitalisation, and/or the injection of hyaluronic acid, such as skin boosters
• Vitamin and mineral injection treatments
• Platelet rich plasma therapy
• Biofiller
• Injection microsclerotherapy
• Weight loss injections
• Carboxytherapy and the infusion of gases under the skin
• Cellulite subcision
• Injection lipolysis with a prescription-only medicine
• Cryolipolysis
• High-intensity focused ultrasound, including intimate use
• Radiofrequency treatments
• Plasma ablation/fibroblast
• Non-ablative lasers
• Medium-depth peels that involve full-thickness destruction of the entire epidermis into the upper dermis
• Prescription-only medication treatments applied topically
• Electrocautery
• The combination of two or more technologies in a hybrid device
• Cryotherapy and/or any cryoautery procedure that freezes the skin to remove any skin lesions.

Red procedures which present the highest risk of complications would only be able to be carried out by regulated healthcare professionals working out of CQC-registered premises. These procedures would also be considered a CQC-regulated activity, like cosmetic surgery, and therefore under their supervision. Currently, the proposed red procedures are:

• All thread-lifting procedures
• Hair restoration surgery
• Procedures aimed at augmenting any part of the body, in particular the breast, buttocks, and genitals, typically using autologous fat or dermal fillers
• Dermal micro-coring
• Hay fever injections for reducing redness or blotches on the skin
• The combination of ultrasound and large bore cannula for liposuction
• Deeper chemical peels (e.g. phenol peels)
• Lasers which target the deeper layers of the dermis (CO₂ Lasers, ablative)
• All intravenous injectables and infusions
• The provision of any procedure where the circumstances of the procedure could be considered the treatment of a disease, disorder, or injury.

The Department of Health and Social Care is also proposing that any procedures included within the licensing scheme should not be carried out on people under the age of 18.

The main feedback the DHSC are looking for is the answers to the following questions. They are asking for feedback from aesthetic professionals but also members of the public who may have had aesthetic procedures.

1. Do you agree with using the three-tier system to classify the different oversight categories for cosmetic procedures?
2. Do you agree with the categorisation of the procedures? (This question is separated by tier to allow for a more detailed response)
3. Do you agree with the DHSC proposal to restrict specific procedures by amending the CQC regulations to ensure that they can only be undertaken by healthcare professionals operating out of a CQC registered premises?
4. Do you agree that it should be a condition of the licence that specified procedures can only be performed on people aged 18 or older?

For more details and explanations about the consultation, you can watch the video below from the Joint Council for Cosmetic Practitioners or visit their website.

To submit your thoughts about the proposed licensing, you can take part in the consultation here.