By the time you read this editorial, the long-awaited Open Public Consultation into the Licensing of Cosmetic Procedures (The licensing of non-surgical cosmetic procedures in England, 2023 2 September) will have closed and the data will be being deliberated by the hard working civil servants within the Department of Health and Social Care (DHSC).
The intention of the licensing scheme is to ensure that those who offer the specific, named list of procedures within the consultation document are:
- Suitably knowledgeable
- Trained and qualified
- Hold appropriate indemnity cover
- Operate from premises which meet the necessary standards of hygiene, infection control and cleanliness.
This is the first consultation on a licensing scheme for cosmetic interventions and the DHSC are looking for the public's views on the procedures within scope, the restrictions on which practitioners should be permitted to perform procedures and the age restrictions for those undergoing such procedures.
The aim of this intervention is to reduce risk by consolidating both the healthcare and lay providers within a dual providers and premises licence that will permit the interventions to take place by the persons licensed, all within the control of the local authorities. I have witnessed a rare phenomenon over this consultation exercise: there has been a resounding agreement within the aesthetic sector and wider public that regulation is necessary. Nevertheless, there is also much controversy and debate regarding the nuts and bolts on how this consultation is being conducted, and how and where it will end up. We asked 10 patients in clinic last week to look at the survey and take the time to read, complete and submit it. All 10 had difficulty and asked us for assistance in completing it. Some did not understand what the lists of named procedures were, or the significance of the risks associated with them. They would have been none the wiser had it not been for the red, amber or green traffic light system, leading them to believe that these procedures had been categorised for risk with green being little or no risk to red alerting them to danger. Furthermore, none of our patients could appreciate or understand why the DHSC was spending time and taxpayers' money on this exercise at this point in time. Particularly when, as they told us, ‘There are now millions of patients sitting on very long waiting lists to access NHS services.’
We must accept that patients like ours, who access their aesthetic treatments via healthcare providers, will have a different viewpoint from those whose providers are outside of healthcare. Equally, the lay groups will also have a different understanding and interpretation of the consultation exercise than we do as healthcare clinicians. However, rather like our patients, our clinical team and many of our healthcare colleagues, are perplexed on how this exercise was signed off at the highest level and published in the first place, when there is no evidence that it will reduce harm. Particularly at a time when our local authority services are already stretched with their present responsibilities. We heard just last month that some of them, like Birmingham Council (Ambrose, 2023) have neither the human nor financial resources to fulfil this undertaking, having recently filed for bankruptcy Regulation will need to be pursued on a stronger basis than this.