The Joint Council for Cosmetic Practitioners is seeking responses to its 10-point plan from all stakeholders
The Joint Council for Cosmetic Practitioners (JCCP) places public protection and patient safety at the core of its activities. Since its official establishment in 2018, it has striven to enhance public protection and safety in the non-surgical and hair restoration surgery sectors. It has achieved notable successes working with a wide range of stakeholders, partners and sponsors.
The past year has been a most challenging time for all people engaged in the non-surgical and hair restoration sector, but it has also seen major advances, as the issues around regulation and public/patient safety have risen to the surface. Many unresolved issues relating to regulation have been highlighted during the debate around COVID-19 and public protection and its impact on the operation of businesses in the sector.
Following the establishment of the All-Party Parliamentary Group (APPG) on Beauty, Wellbeing and Aesthetics, Private Member Bills around age of consent for advanced treatments, the inappropriate use of social media and major advances in regulation in Scotland and Wales have all escalated the UK debate about regulation.
As the COVID-19 pandemic has presented many with additional time that they would not usually have, the JCCP has grasped this opportunity to consider the bigger picture surrounding the future of the aesthetics sector. It has mapped out an overarching strategy and plan that can be used to inform and address the many issues relating to regulation, patient safety and education and training. The JCCP has seen numerous individual campaigns, initiatives and policies promoted by the many disparate stakeholders within the aesthetics sector, but 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. It is in this context that the JCCP has established its 10-point plan for the sector.
Identifying 10 key policy areas
The JCCP has used its key contacts with service users, the Government, regulators, professional regulators, bodies and associations, pharmaceutical companies, pharmacies, education and training providers, insurance companies, practitioners and many others to identify 10 key policy areas where significant changes are required, and these are set out the 10-point plan (Figure 1).
Figure 1. The 10-point plan
In each of the 10 policy areas, the JCCP has identified the following:
- The area in need of action
- The issues surrounding the areas
- Objectives
- Proposals.
The plan itself is not prescriptive, and the JCCP accepts that, in many areas, there will be differences of opinion on potential actions/proposals. However, it does believe that there is also considerable consensus with regard to a call to action to address key issues that relate to patient safety, public protection and recognition of aesthetic practice as a cognate and responsible profession in its own right.
Both the public and aesthetic practitioners will find the areas of action clear and simple, and a wider document outlining the intricacies and proposals can be found on the JCCP website for further elaboration. This document goes some way into detangling the copious problems than are seen in the UK non-surgical sector, but it is by no means exhaustive. When forming objectives and proposals, the JCCP has listened to a wide range of people, from the public and practitioners to Government bodies, and it will continue listening and adapting where it sees scope to do so.
Setting out a plan
The non-surgical cosmetic and hair restoration sector has grown rapidly, and the speed of growth has outpaced the capacity to build an effective and coherent regulatory framework, leading to major gaps existing in regulation and in the infrastructure to deliver safe and accountable practice for the general public. This is not to say that there are not many areas of outstanding practice, but the many horror stories relating to adverse treatment outcomes that pervade the press and social media platforms every day must also be accepted.
In the JCCP's experience, there is evidence that, at all levels, and across all stakeholders, there is a desire and passion to deliver high-quality, safe and accessible treatments, although there are many strong and divided opinions on how to do this. This can result in dissonance and distract the many admirable practitioners who strive to place the delivery of harm-free and effective treatments at the heart of their practice.
The issues around regulation, medical categorisations, education, products and practitioners are lengthy and confounding, and, as a council, we still unravel layers of complexities on a regular basis, despite our years of combined experience and work together. This is also true for experienced practitioners who have become well versed in the problems that the sector faces and the threats to public safety, but it is important to remember and acknowledge that not every practitioner, and certainly not members of the public, are as well-acquainted with these interlocking problems. The 10-point plan lays out these problems in more digestible and deliverable points, with the JCCP's full review expanding on the issues where needed.
» In 2021, there are some critical deadlines where there is the opportunity to influence Government policy as it considers and debates the key issues that are endemic in the sector «
The lack of a collaborative and co-ordinated approach across the sector also makes it extremely difficult to persuade the Government and regulators of the need for change. This problem is further exacerbated by the lack of research and data on the sector, which leads to anecdotally driven campaigns that are doomed to fail. Much of the evidence and data is held individually by the stakeholders but not shared for various reasons, both commercial and political.
The JCCP believes that there is a strong willingness for the sector to come together, debate its priorities for action and to present a united and committed approach to the Government and regulators. To do this, the sector must be able to agree on the issues to be addressed and to each contribute resources and expertise to delivering this plan to the key decision-makers.
Next steps
The JCCP has set out its proposed 10-point plan, supported by the underpinning identification of specific proposals, and welcomes inputs and comments from all stakeholders.
In 2021, there are some critical deadlines where there is the opportunity to influence Government policy as it considers and debates the key issues that are endemic in the sector. The APPG on Beauty, Wellbeing and Aesthetics is likely to publish its recommendations around June 2021, after which, the Government will consider its response. Many have submitted individual responses to the APPG, but nowhere is there an overarching plan that sets out how many individual suggestions can be embodied in a considered and clear plan. The Scottish Government has also recently concluded a public consultation on regulation which is due to report shortly.
Therefore, the JCCP is seeking responses to its 10-point plan from all stakeholders by 31 May 2021 so that it can amend, update and improve this draft plan. It is then the intention of the JCCP to present this to the Government and regulators.
All responses need to be sent to: admin@jccp.org.uk.
For further information on the 10-point plan, please contact the JCCP's Executive Chair, Professor David Sines: david.sines@jccp.org.uk.