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Staying in control

In any oth­er area of med­i­cine you would expect gov­ern­ment reg­u­la­tion to be in place to ensure safe­ty and stan­dards were being met. Yet, when it comes to cos­met­ic pro­ce­dures, the reg­u­la­to­ry are­na has become a mine­field, putting con­sumers at risk from unscrupu­lous prac­ti­tion­ers try­ing to cash in on the lucra­tive anti-age­ing mar­ket.

While the cos­met­ic surgery sec­tor is reg­u­lat­ed by the Care Qual­i­ty Com­mis­sion (CQC) and oper­at­ing facil­i­ties are inspect­ed to make sure they meet stan­dards, the pub­lic can still fall foul of rogue prac­ti­tion­ers labelling them­selves as cos­met­ic sur­geons when they are not actu­al­ly qual­i­fied to do so.

Harley Street has become syn­ony­mous with cos­met­ic surgery, but it is impor­tant to remem­ber that Harley Street is an address not a qual­i­fi­ca­tion, so the only way to safe­guard your­self is to always check that your sur­geon is on the spe­cial­ist reg­is­ter with the Gen­er­al Med­ical Coun­cil (GMC).

For peo­ple seek­ing less inva­sive forms of cos­met­ic enhance­ment, how­ev­er, it is not so cut and dry. The non-sur­gi­cal sec­tor is one of the biggest growth areas, par­tic­u­lar­ly when it comes to cos­met­ic injecta­bles, such as bot­u­linum tox­in (Botox®) and der­mal fillers, but the lack of reg­u­la­tion sur­round­ing it has made it dif­fi­cult for con­sumers try­ing to find a safe and eth­i­cal prac­ti­tion­er.

Since the gov­ern­ment made the some­what con­tro­ver­sial deci­sion not to impose statu­to­ry reg­u­la­tion on this boom­ing mar­ket, every­one from vets to beau­ty ther­a­pists and podi­a­trists have been try­ing to take a bite of the cos­met­ic injectable pie. But with demand ris­ing every year, the need for some form of con­trol was huge­ly appar­ent.

After six years of dis­cus­sion between the indus­try and the Depart­ment of Health, it seemed as if there was final­ly a light appear­ing at the end of the tun­nel when, in Sep­tem­ber 2010, the Inde­pen­dent Health­care Advi­so­ry Ser­vices (IHAS) launched its Reg­is­ter of Injectable Cos­met­ic Providers, known as Treat­ments You Can Trust (TYCT). The aim of the scheme is to pro­vide indi­rect reg­u­la­tion through the Health and Safe­ty at Work Act, Med­i­cines Act and pro­fes­sion­al fit­ness-to-prac­tice con­trols (name­ly the GDC, GMC and NMC), and to encour­age mem­bers of the pub­lic to choose providers that have been award­ed its Qual­i­ty Assur­ance Mark.

TV’s Dr Hilary Jones, who is a mem­ber of the TYCT Gov­er­nance Group, which has been set up to estab­lish the inde­pen­dence of the reg­is­ter, says: “Any­thing we can do to make it eas­i­er for con­sumers to find an appro­pri­ate provider in a safe envi­ron­ment is a major step for­ward.”

Unlike lip­stick and mas­cara, these treat­ments are seri­ous med­ical pro­ce­dures with seri­ous risks attached

The scheme is now grow­ing in strength but with many clin­ics being slow to sign up for the vol­un­tary reg­is­ter, indus­try bod­ies, such as the British Asso­ci­a­tion of Cos­met­ic Doc­tors (BACD), have been doing their own part to pro­mote the safe and eth­i­cal prac­tice of cos­met­ic med­i­cine. Chair­woman Dr Saman­tha Gam­mell says: “We vet all of our mem­bers and also have a star-rat­ing sys­tem on our web­site so patients can see whether the doc­tor has met our more advanced cri­te­ria.”

One area that the IHAS is crack­ing down on is the issue sur­round­ing the use of cos­met­ic injecta­bles by beau­ty ther­a­pists.

“Beau­ty ther­a­pists are not allowed to car­ry out bot­u­linum tox­in treat­ments in the UK full stop,” says Sal­ly Taber, direc­tor of the IHAS. “They are not med­ical­ly trained and there­fore can­not pre­scribe or admin­is­ter the treat­ment legal­ly, as it is a pre­scrip­tion only med­i­cine.”

But it is in the area of der­mal fillers that a loop hole or grey area exists and it is this that caus­es the IHAS, and the indus­try at large, the most con­cern. Fillers are clas­si­fied as med­ical devices rather than med­i­cines and there­fore it is not actu­al­ly ille­gal for a non-medic to admin­is­ter them, how­ev­er fillers can poten­tial­ly cause last­ing dam­age. “It’s extreme­ly con­cern­ing that the law cur­rent­ly allows beau­ty ther­a­pists to car­ry out injectable cos­met­ic treat­ments. TYCT will cat­e­gor­i­cal­ly not accept these indi­vid­u­als on to the reg­is­ter,” adds Ms Taber.

Dr Gam­mell com­ments: “Injectable treat­ments are increas­ing­ly becom­ing part of our dai­ly beau­ty vocab­u­lary but, unlike lip­stick and mas­cara, these treat­ments are seri­ous med­ical pro­ce­dures with seri­ous risks attached. It may be cos­met­ic but it is still med­i­cine.”

While peo­ple are often ful­ly aware of the risks of cos­met­ic injecta­bles, many under­es­ti­mate the dan­ger of lasers. A burn from a laser can be extreme­ly seri­ous, which makes it even more shock­ing that, in Octo­ber 2010, the gov­ern­ment decid­ed to dereg­u­late cos­met­ic lasers and intense pulsed lights (IPL) for cos­met­ic uses.

This means that although the CQC con­tin­ues to reg­u­late all health­care pro­fes­sion­als using lasers and IPLs to treat “dis­ease, dis­or­ders or injury”, the beau­ty sec­tor now falls out­side of its remit, leav­ing non-med­ical­ly trained prac­ti­tion­ers to treat clients with­out being account­able.

Dr Philip Dob­son, med­ical direc­tor at LCS Health­care, says: “The reg­u­la­tions have been framed so as to reg­u­late the med­ical sec­tor to the high­est pro­fes­sion­al stan­dards for car­ry­ing out pro­ce­dures, where­as, iden­ti­cal treat­ments per­formed by beau­ty ther­a­pists, includ­ing advanced skin abla­tion, could be done per­fect­ly legal­ly on their kitchen table, with­out any statu­to­ry reg­u­la­tion or even med­ical super­vi­sion.”

With feel­ings in the indus­try about de-reg­u­la­tion still run­ning high a year after the changes were imposed, the IHAS has been work­ing along­side indus­try bod­ies to set up a sim­i­lar qual­i­ty mark for cos­met­ic lasers and IPLs, which could come into place ear­ly in 2012.

But all this is not meant to scare­mon­ger the beau­ty seek­ing pub­lic. In the right hands, cos­met­ic pro­ce­dures are incred­i­bly safe, as long as you remem­ber that the right hands should be med­ical — and they should be account­able.

SAFEGUARDS

  • Look for cos­met­ic injectable providers with the TYCT Qual­i­ty Assur­ance Mark.
  • Make sure your sur­geon is on the Spe­cial­ist Reg­is­ter with the GMC or that your den­tist, doc­tor or nurse is reg­is­tered with their rel­e­vant pro­fes­sion­al body (GDC , GMC , NMC).
  • Use the “find a surgeon/doctor” loca­tors on the BAAPS or BACD web­sites.
  • Don’t be afraid to ques­tion your prac­ti­tion­er about their expe­ri­ence and qual­i­fi­ca­tions.
  • Make sure you have a thor­ough con­sul­ta­tion.
  • Do not go to a beau­ty ther­a­pist or non-medic for cos­met­ic injecta­bles.