Professor David Sines 
The 10-point plan received over 400 responses from stakeholder members of the aesthetic sector
In March 2021, the Joint Council for Cosmetic Practitioners (JCCP) considered the future of the aesthetics sector and mapped out an overarching strategy and plan that could be used to inform and address the many issues relating to regulation, patient safety, education and training. The JCCP is committed to enhancing and strengthening patient safety and public protection, but the organisation acknowledges that, at the present time, what has been lacking is a clear, transparent and easily understood framework within which all stakeholders can engage and contribute to achieve sustainable system change and service improvement. It is in this context that the JCCP published a 10-point plan for regulation within the aesthetics sector. At the heart of the proposal is a ‘call to action’ from all stakeholders to address key issues that relate to patient safety, public protection and recognition of aesthetic practice as a cognate, specialist and responsible profession.
The JCCP acknowledges that there is a desire and passion to deliver high-quality, safe and accessible aesthetic treatments and services; however, there are many strong and divided opinions on how to achieve this. Despite these differences, the JCCP believes that there is a strong willingness for the sector to come together, debate its priorities for action and present a united and committed approach to the Government and regulators. The 10-point plan sets out the key parameters that are required to address the multiple challenges that exist within the sector. It is the JCCP's hope and aim that, by adopting a concerted and unified approach to addressing the issues set out in the plan, it will result in the achievement of systemic and responsive change within the sector, with the primary aims of improving service user safety and quality of experience, while, in parallel, promoting excellence and pride within the aesthetic profession itself.
Responses to the 10-point plan stakeholder consultation
Since the publication of the 10-point plan in March 2021 (JCCP, 2021a), the JCCP has received over 500 responses from stakeholder members of the aesthetics industry. The results are overwhelmingly in favour of the JCCP's call to implement a national system of regulation and licensing, supported by universal agreement that the UK Government should mandate the requirement for all practitioners to be able to evidence that they possess requisite knowledge and evidence-based practice prior to being able to administer medical aesthetic procedures. The JCCP considered that such knowledge and competence should be determined against a nationally agreed and mandated framework of education and practice standards.
Support for statutory regulation and licensing
Analysis of the responses received by the JCCP to the plan shows full support (98%) for the call that statutory regulation and licensing should be introduced in the UK for the non-surgical aesthetic and surgical hair-restoration sector. Responses were particularly strong in the call for regulation to be introduced for non-health professionals to perform less invasive procedures. This group was noted to be ‘rapidly increasing in numbers’, presenting with ‘inconsistent and often absent prior training and supervision’ and not having the ability to or knowledge of how to respond to potentially harmful adverse incidents.
Central also to the responses were comments such as ‘training academies have reached almost epidemic proportions, with anyone seemingly able to train others without formal teaching qualification or monitoring’. Some 85% of respondents advised that ‘this is unacceptable’, and most called for all training organisations to be formally approved and to employ proficient trainers and educators with formal teaching qualifications and professional knowledge to ‘ensure transparency and consistency for all being trained in this sector’. One respondent advised:
‘Healthcare professionals have a duty of care and that of ensuring they are continuously updating and revalidating. I am truly frightened at how this sector has become and that we are the laughing stock of many countries, due to who we allow to pick up a needle and inject’.
Many respondents also advised the need for all clinics to display both their insurance and education/training certificates in the interests of public transparency.
» … 100% of respondents advised that no medical prescribing professional should be permitted to prescribe any medications in the absence of a face-to-face assessment of the patient «
Support for robust assessment and face-to-face consultation
Over 85% of respondents emphasised the importance of ensuring that practitioners apply robust, evidence-based physical and psychological assessment protocols and face-to-face consultations with their patients to ensure, first and foremost, suitability for treatment. Respondents also noted the importance of applying the Montgomery ruling of informed consent (Chan et al, 2017), with an emphasis on explaining the risks and benefits of the proposed treatment(s), which allows the patient to be well informed and have the ability to consent.
Concern surrounding advertising and social media
More than 90% of respondents expressed a significant concern regarding the proliferation of exaggerated, unsafe and, in some cases, false social media posts that advertised both practitioner services and access to sub-standard education and training. For example, many advised that social media platforms have recently shown ‘how little knowledge is actually out there, with untrained practitioners frequently asking about very basic issues, such as asking where they should inject’. The JCCP has also witnessed social media posts advising that members of the public can train in 24 hours to become ‘fully competent to administer invasive treatments, such as injectables or dermal fillers’, while others have even been advised that ‘insurance is not required to practice’. Additionally, of key concern is the fact that prescription-only medicines (POMs) continue to be regularly advertised on social media and offered at a ‘bargain price’. Despite reporting this to the relevant bodies, such practices continue.
Support for premises standards
Unsurprisingly, 97% of respondents were in full support of the JCCP's call for all clinics to abide by nationally agreed premises standards, including the need to assure compliance with infection-control and health-protection standards.
Defining medical procedures
The JCCP has also called for greater clarity to be produced regarding the definition of medical, medically related and cosmetic treatments. Over 82% of respondents supported the need for a definitive statement to be produced, and, in response, the JCCP has now published its own definitive statement on this subject (JCCP, 2021b). The JCCP's statement seeks to ensure that only suitably trained and competent health professionals both assess and treat patients who present with medical or medically related conditions. As one respondent advised, ‘all treatments will change an appearance cosmetically/aesthetically, but the mere fact that ‘medical’ tools are used in assessment and delivery deems this a medical treatment, which should only be delivered by fully trained and qualified healthcare professionals’.
Prescribing support standards
Prescribing forms a key section in the 10-point plan. This section received overwhelming support, and 100% of respondents advised that no medical prescribing professional should be permitted to prescribe any medications in the absence of a face-to-face assessment of the patient, while 76% advised that prescribers should not be permitted to prescribe POMs to a non-medical individual in the absence of on-site healthcare supervision (i.e. in the absence of the knowledge and competence required to correct adverse events in emergency situations). In support of this, these matters have now been referred by the JCCP to the Royal Pharmaceutical Society as part of their consultation for a revised prescribing framework.
Prescription dermal fillers
One area that attracted a more disparate response was related to the JCCP's call that dermal fillers should become prescription-only devices. While 74% of respondents unequivocally agreed with this recommendation, the remaining 26% considered that the call to introduce further restriction on the supply of dermal fillers was disproportionate to the level of risk to patient safety. The JCCP will now refer this matter for more detailed consideration to its Clinical Advisory Group to determine further action.
Support for complications reporting and insurance
Some 90% of respondents were in favour of the Medicines and Healthcare products Regulatory Agency (MHRA) introducing a modified, accessible and comprehensive national complications reporting system. Similarly, 98% of respondents were in full agreement with the proposal to ensure that all practitioners held adequate medical insurance cover and provided access to a reputable and trusted patient redress scheme.
The need for patient information and safe products
The importance of providing members of the public with accessible, honest and balanced information about treatments was supported by all respondents. Raising awareness of the benefits and risks associated with aesthetic treatments with members of the public was noted to be pivotal in the shared endeavour to provide public protection and informed choice. Similarly, all but two respondents advised their support for practitioners to ensure that the products that they used were ethically sourced from reputable suppliers (preferably endorsed by a CE mark). Respondents also noted their concern about the proliferation of social media posts that advertised and promoted ‘cheap unregistered products, most unsafe with no CE mark and the inability to respond to agents that reverse their actions, causing greater harm and discomfort to the patient’. Respondents also expressed concern about the unmitigated stress and pressures placed on patients and the NHS more generally due to the need for ‘individuals who have either been left with no professional support or aftercare or told to go to the NHS emergency department if they experience complications or adverse events’.
» Over 78% of respondents considered that the Government should determine (in legislation) those practitioners who should be legally considered to be knowledgeable, competent and trained to deliver the more invasive aesthetic procedures «
Who should provide treatments
Finally, it is significant to note that over 78% of respondents considered that the Government should determine (in legislation) those practitioners who should be legally considered to be knowledgeable, competent and trained to deliver the more invasive aesthetic procedures, including hair restoration surgery, threads, deeper chemical peels, lasers and dermal fillers and injectables. As one respondent advised, ‘there is no control over who or what type of toxin or filler, etc, is being used to treat the public. This is a specialist job, so why and how can anyone pick up a syringe and one of the most toxic substances there is and inject it into someone's face?’.
The JCCP has been delighted with the support that it has received for its 10-point plan, and the council will continue to review further responses. We will actively engage with members of the public and the aesthetic sector to determine how best to proceed to advise and seek Government support for the implementation of a UK-wide system of regulation and licensing. The system will need to be flexible enough to accommodate to the specific needs of each national devolved administration and enhance both public protection and patient safety within the aesthetics industry.