Dr Singh who runs his botox clinic in Stevenage, Hertfordshire, in his latest blog shares his thoughts on botox and regulation.
In 2013, the Department of Health predicted that the value of the cosmetic surgery industry in the UK would rise from £2.3bn in 2010 to £3.6bn in 2015. This is certainly something that many dentists are becoming more interested in offering their patients, since they are ideally placed, once appropriately trained, to deliver non-surgical facial aesthetics complementary to dental treatment. With this in mind, dentists need to know from the outset what regulatory framework exists to help keep patients safe.
Overseeing cosmetic care
Currently, there is no regulatory body or any formal process of regulation regarding the administration of non-surgical facial aesthetics. However this will be changing in the not too distant future – more on this later. In the meantime, there are, of course, bodies that regulate dentists (and their requirements will apply to dentists who carry out facial aesthetics).
Initially, the GDC did not see the provision of facial aesthetics services as part of the act of dentistry but this changed several years ago. Now non-surgical aesthetics comes under there remit of dentistry. Therefore, the GDC expects any practitioner to provide the same level of care and competence for this service as they would for dental treatment.
All of the GDC’s Standards need to be applied to the facial aesthetics business, namely:
• Standards for dental professionals
• Principles of patient consent
• Principles of patient confidentiality
• Principles of dental team working
• Principles of complaints handling
• Principles of raising concerns
• Principles of management responsibility
• Principles of ethical advertising.
If you are providing facial aesthetics within your dental practice, then it will come under the Care Quality Commission’s (CQC) remit. If you are providing these services away from your premises, then currently it will not. However, bear in mind that irrespective of your premises, if you are treating hyperhidrosis (excessive underarm sweating), the CQC may feel it comes under their remit. This is because hyperhidrosis is classed as a disorder that must be diagnosed before any treatment can be provided. It is further defined as such by the NHS. This makes it a ‘regulated activity’ within the CQC in England (with similar requirements in Wales, Scotland and Northern Ireland).
Looking to the future, as a result of the PIP implant scandal, Sir Bruce Keogh was asked by the Department of Health to investigate the cosmetic interventions industry. He was asked to look at:
• Standards for cosmetic surgery practice and training
• Fillers as a POM (prescription only medicine)
• Record of consent
• Advertising restrictions
• Professional indemnity cover.
The Keogh report was produced in April 2013 and the Government responded to it in February 2014. Work is underway to create documentation and, where necessary, legislation to implement a number of the key recommendations, which included:
• A register of everyone who performs surgical or non-surgical cosmetic interventions
• Classifying dermal fillers as a prescription only medical device
• Ensuring all practitioners are properly qualified for all the procedures they offer
• All non-surgical procedures must be performed under the responsibility of a clinical professional who has gained the accredited qualification to prescribe, administer and supervise aesthetic procedures
• A ban on special financial offers for surgery
• An advertising code of conduct with mandatory compliance for practitioners
• Compulsory professional indemnity in case things go wrong
• An ombudsman to oversee all private healthcare, including cosmetic procedures, to help those who have been treated poorly.
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