Aesthetic practitioners respond to JCCP plan

A group of over 100 doctors, nurses and dentists from the field of aesthetics have come together to issue a response to the JCCP (Joint Council for Cosmetic Practitioners) in reference to its 10-Point Plan.

The Plan, released in March, is a framework of recommended actions towards regulation and a monitored, safer environment for the practise of non-surgical aesthetic procedures, including hair restoration.

See below infographic for the 10-Point Plan in brief.

Represented by Dr Steven Land, director of Novellus Aesthetics, Ness Griffiths, aesthetic nurse practitioner at Novellus Aesthetics; and Dr Tapan Patel, director of Phi Aesthetics, the response addresses each point individually and summarises “the general feelings about this plan from those operating within the sector”. The main body of the letter reads as follows:

Point 1 – Statutory regulation:

“We would start out by pointing out that those we feel should be injecting – doctors, dentists and nurses – are already mandated to be on a statutory register. Entry onto these registers compels them to ‘follow best practice guidance’; ‘comply with standards of proficiency’; ‘provide treatments safely’ and ‘possess (any) insurance cover’. It is our belief that legislation restricting practice to the aforementioned groups would solve many of these problems in one go and thus this point does not actually go far enough.

“Lobbying and exerting political influence to this end would be a more useful effort than trying to set up another compulsory register when it is not needed and would in fact be a huge leap forward in making the whole industry safer. Working with these regulatory bodies – NMC, GMC and GDC – to encourage them to take aesthetic medicine more seriously as a speciality and develop their own guidelines and policies would be welcomed by everyone in the sector.”

Point 2 – Mandatory education and training standards:

“Much in this point is to be applauded – working to raise the training and educational standards within aesthetic medicine is paramount. We would point out that restricting the practice of aesthetic medicine to doctors, dentists and nurses would solve a lot of the issues around maintaining competence and being registered on a PSA register would add the proposal of working with these registers to ban their members from training those unqualified to undertake medical procedures.”

Point 3 – Clear, transparent information:

“Again, much to be recommended in this point – and again all of this would be covered under the duties expected by the relevant registering bodies of doctors, dentist and nurses. Restrict practice to these groups, work with their registering bodies for clear guidance on aesthetic medicine for their members and a regulatory framework to prevent poor practice already exists.”

Point 4 – Definition of medical and cosmetic treatments:

“This is a point that we have issue with. We would contest that any procedure using a prescription-only medicine or a class-three implantable medical device is medical. It may also be cosmetic as the two are not mutually exclusive, and to try and set such distinction is unfair (as a comparison, we would point out that the majority of breast augmentation surgery (using an implantable medical device) is for cosmetic reasons but is also self-evidently medical).

“The recently published WHO ICD-11 classifies everything we treat with botulinum toxin and dermal filler to be a disease. Aesthetic medicine is considered a medical speciality in its own right in other countries and restricted to medical practitioners – and it should be so in this country, too.”

Point 5 – Safe and ethical prescribing:

“Again, much to be commended in this point – particularly the objectives of publishing details of practitioners’ prescribers (perhaps as part of the licensing scheme mentioned in Point 9) and the proposal that all prescribing professionals are allowed to obtain stock for emergency purposes – both of which would increases safety for our patients.

“We would also add that working with the GMC, GDC and NMC to adopt the 2019 GPharmC guidance on not prescribing for non-medical professionals in the field of aesthetic medicine would be welcomed by advocates of patient safety.”

Point 6 – More regulated advertising and social media:

“Again, nothing here to argue with, suffice to say that current rules and regulations need to be more strictly enforced to ensure a level playing field. As fillers are considered a medical treatment by their regulatory bodies, medical practitioners are not allowed to do any sort of offer, whereas non-medical practitioners are free to do what they will (again, restricting aesthetic medicine to medics would solve this problem).”

Point 7 – National complications reporting:

“We agree that making dermal fillers prescription-only devices should lead to an increase in complication reporting, especially if this is made easier with an online reporting form or app. Pushing for regulation around medical devices (which have notoriously poor vigilance) may be easier as it removes the requirement for reclassification and would improve the safety of medicine as a whole.”

Point 8 – Adequate insurance cover:

“Another laudable aim, entirely covered by making aesthetic medicine practice-able only by medics. Membership of our respective mandatory registers makes us compelled to have adequate insurance for the fields within which we practice.”

Point 9 – Licensing of premises, treatments and practitioners:

“This point and its objectives go a long way toward making the field of aesthetic medicine more regulated and safer for the patient. Licensing of premises to ensure they meet basic requirements, details of the treatments carried out and the details of the practitioners working there, and their regulatory bodies, prescribers and qualifications would seem so obvious that we suspect most members of the public would be surprised to find out it doesn’t already happen.”

Point 10 – Raising customer awareness:

“Any proposal to raise public awareness of aesthetic medicine, its benefits and its risks is to be applauded. The availability of reliable information is key to safe decision making by our patients – knowing what procedures available, safe and well evidenced and which practitioners can be relied upon to do right by them is paramount to the safety of our patients and the continued success and growth of aesthetic medicine as a speciality.”

The authors added: “As general points we would like to say we have issues with the impartiality of the APPG for beauty, aesthetics and wellness. It is funded by the beauty industry and previous public meetings have shown they have little understanding of the medical aesthetics field and the complexities contained therein.

“We believe that closer ties with the current regulatory bodies for doctors, dentists and nurses are key relationships for moving the safety of aesthetic medicine forward – many of the points covered in this document should be being regulated by these bodies for their members yet are seemingly ignored even when concerns are reported.”

The JCCP has partnered with Learna on a fast-track pathway to joining Part One its Practitioner Register.