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‘We must work together for a safer cosmetic industry’

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Ensure you are up to date with the latest guidance from the NMC on cosmetic injectables, says Sally Taber

The events surrounding Poly Implant Prothese (PIP) implants at the end of 2011 turned the spotlight on the regulation of the UK cosmetics industry and this year has seen a fundamental shake-up of the cosmetic treatments industry.

The most recent significant announcement has come from the General Medical Council (GMC) stipulating that doctors are to be banned from prescribing Botox by phone, email, video-link or fax. The GMC guidance led to further announcements by the Nursing and Midwifery Council (NMC) on remote prescribing by registered nurses. The NMC guidance states that remote prescriptions should not be used as a routine means to administer injectable cosmetic medicinal products and gives advice on the standards for appropriate care. The General Dental Council (GDC) has also updated its guidance for dentists. Both the NMC and GDC had already stipulated that registered nurses and dentists should not be doing it anyway.

‘I welcome these announcements as the fruition of a long campaign for an end to the practice of remote prescribing’

As director of the Independent Healthcare Advisory Services (IHAS) and of the government backed scheme Treatments You Can Trust (TYCT), I welcome these announcements as the fruition of a long campaign for an end to the practice of remote prescribing.

The safety of patients undergoing cosmetic treatments is at the centre of the work of Cosmetic IHAS but I am now listening to the practical implications of these announcements. The GMC finally ending the affair of remote prescribing has not been universally welcomed because the cosmetics industry has proved a lucrative business for some practitioners who have built their businesses (in some cases, million-pound businesses) on remote prescribing.

It was recently reported by BBC London that a doctor was misleading nurses over Botox prescriptions. It was reported that he told nurses that Botox prescriptions could be acquired in one person’s name for use on someone else, despite this being banned. The fact that registered nurses believed this doctor rather than their nursing regulator has surprised the TYCT governance board.

The new language of remote prescribing now appears to be focused on repeat prescriptions for Botox or Botulinum toxin, which provides a temporary solution to winkles caused by the ageing process. Typically a single treatment with botulinum toxin lasts around 3-4 months and it’s likely that patients will be advised to receive repeat treatment. Given that the patient needs to visit a trained aesthetic healthcare practitioner (doctor, dentist, nurse prescriber or nurse) for this repeat treatment, is it reasonable to expect that a nurse who is not a prescriber may be able to administer additional treatments following the initial assessment by the doctor, dentist or nurse prescriber?  The question has been asked could patient group directions be used to enable the trained medical aesthetic nurse to administer repeat treatments?

The regulatory bodies have made it very clear that remote prescribing has to stop. The question that should be asked when repeat prescriptions are being suggested is: “How often does a patient’s care plan need to be updated?” My warning to those considering this way forward is to also ask: “Does this prescription need updating and therefore do I need the patient to have a face-to-face consultation with the prescriber?” We need to ensure that we put patient safety first.

The NMC guidance also reminds nurses that like all medicines, injectable cosmetic medicinal products can cause side-effects and adverse reactions. If a reaction occurs, although the prescriber would be liable for prescribing, the nurse or midwife would be accountable for their assessment of the person and the administration of the medicinal product.

The other issue that is of concern to those that strive to attain high standards in the industry is just how far does the foot extend to? Podiatrists now appear to think that they are appropriate to be giving cosmetic injectables. Supplementary prescribers like podiatrists now want to work in a buddy scheme. If their professional bodies do not regulate them as they are acting outside of their scope of practice, they will be unregulated and uninsured.

TYCT is advocating that only appropriately trained doctors, dentists and registered nurses should be undertaking these treatments. The scheme uses indirect regulation namely the three professional regulators, the Medicines Act and the Health and Safety Act, section 3, which ensures an appropriate environment to undertake cosmetic injectables.

We must police rogue practitioners who continue to remote prescribe despite the new guidance from the GMC, NMC and GDC. One suggestion is for TYCT to have an information sharing protocol to report bad practice to the regulators.

TYCT standards also cover dermal fillers, which are classified as medical devices. IHAS’s long-held position is that the regulation of dermal fillers must be tightened up and it will lobby the recently announced Review of the Regulation of Cosmetic Interventions, being taken forward by the NHS medical director Professor Sir Bruce Keogh, to do just that.

Sally Taber is director of the Independent Healthcare Advisory Services (IHAS) and Treatments You Can Trust

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