What Professor Sir Bruce Keogh called a ‘wild west’ industry, too often remains so, frequently at the peril of innocent patients and the profit of inappropriate operators
Non-surgical cosmetic treatments are invasive treatments designed to alter appearance and self-image. The outcomes can cause significant changes in the mental health of the patient, for better or worse. Permission to do this should only be given to people who are knowledgeable and appropriately trained, with the interest of the patient always of foremost importance. Unfortunately, the evidence shows that, too often in the non-surgical cosmetic industry, this is not so. What Professor Sir Bruce Keogh called a ‘wild west’ industry, too often remains so, frequently at the peril of innocent patients and the profit of inappropriate operators.
Now is the time to work together to ensure that those providing aesthetic treatments are only practitioners who are appropriately qualified. This will require conscious improvements in collaboration between everyone who believes in high patient safety standards.
Possessing the right skills
For better understanding, let us revisit what has happened in the past. In 2015, Health Education England (HEE), at Government behest and with industry involvement, derived a framework of qualifications resting on a skills and knowledge framework that ensured that those undertaking the most skilful treatments were fully educated. These standards were handed to the Joint Council for Cosmetic Practitioners (JCCP) and the Cosmetic Practice Standards Authority (CPSA). This framework should have been updated and should underpin both knowledge and practice-related competencies within the aesthetics industry. Those who qualify and meet these standards should be registered by the JCCP and held accountable. Unfortunately, too often, practitioners without the defined knowledge and skills are being deceived by unscrupulous training providers into paying for inadequate training, then let loose on an unsuspecting public.
Public protection
The JCCP is a Professional Standards Authority (PSA)-accredited register of the non-surgical aesthetic industry in England and provides an informed and legitimate point of access for the public seeking information about this area of practice and, where appropriate, for raising concerns about practitioners. The JCCP places public protection and patient safety as the focus of its activities. As the JCCP Trustee responsible for receiving and reviewing complaints and concerns, it is very concerning to have witnessed that, in regard to training, there is a significant number of courses provided by training companies who allege that practitioners without a regulated qualification are safe to undertake training at Level 3 and then be fast-tracked to Level 7. It is not only beauty therapists undertaking such accelerated and diluted training pathways, but also numerous regulated professionals. If the industry worked together in the interests of public protection, hopefully this unsafe practice could be halted.
Organisations should work more collaboratively to improve communication channels and to ensure that patient safety issues, such as the requirement to work from safe premises, to use safe and appropriately sourced products and for the delivery of aesthetics treatments to only be carried out by appropriately trained practitioners, are overseen and rules enforced. The JCCP also recognises that training organisations should monitor patient safety and clinical quality and encourage continuous quality improvement.
» The use of deliberately misleading terms, including ‘accreditation’, ‘accredited’ and ‘uni’, is common, and courses are producing inadequately trained practitioners who, perhaps unknowingly, overclaim their skills to the public «
Statutory regulation
The JCCP is a not-for-profit UK charitable body that is charged with the responsibility of voluntary self-regulation of the non-surgical aesthetic sector in the four UK countries. The council was established and launched formally at the House of Lords in February 2018, following an extensive stakeholder consultation process undertaken by HEE in accordance with the recommendations outlined in the Keogh review (2013) on non-surgical treatments in England. The resultant HEE standards were transferred to the JCCP by the HEE in June 2018. One of the key recommendations included in the 2015 HEE report called for the establishment of statutory regulation for the sector, and for the immediate creation of a voluntary register. The JCCP fulfils such a function. Hopefully, statutory regulation will happen, but it certainly has not been achieved yet.
The JCCP has now matured to become a key policymaking body in the aesthetics sector and engages with the main professional statutory regulatory bodies and with Department of Health and Social Care (DHSC) and Scottish Government colleagues to determine regulatory processes and standards for this sector in the interests of public protection and patient safety. These matters have now achieved new momentum within the Government, and the JCCP is actively determining new primary and secondary licensing and regulatory schemes to mandate standards for the sector.
Advertising standards and codes
The JCCP has been working closely with the Committee of Advertising Practice (CAP) and the Advertising Standards Authority (ASA) to strengthen and reinforce advertising standards and codes within the aesthetic sector.
The JCCP is aware of the many concerns that have been raised regarding a number of misleading and exaggerated claims and misleading strategies that have been used to advertise cosmetic treatments to members of the public and to practitioners, including the explicit promotion of prescription-only medicines (POMs), such as botulinum toxin. The use of deliberately misleading terms, including ‘accreditation’, ‘accredited’ and ‘uni’, is common, and courses are producing inadequately trained practitioners who, perhaps unknowingly, overclaim their skills to the public.
An example of a concerning service
An example of a service alarming to the JCCP is a clinic owner who started to offer advice and training for salon owners and industry professionals. She claims to have been involved in the beauty industry for over 20 years but has no regulated qualification. A training academy was opened, and product development and distribution started. The service has an online shop, which offers ‘educational material’ for anyone to buy. Business manuals, PowerPoint presentations, business packs and template training manuals are available to be purchased. The training material covers a wide variety of treatments, including ‘advanced lip techniques’ and ‘advanced Botox’. Such qualifications are defined as Level 7 (i.e. open only to professionals who are qualified at Level 6 or 7, for example, registered doctors, nurses or dentists). Also offered is an ‘advance training programme’, which is purely online, with no hands-on skill training. The price of the PowerPoints range from £45 to £75. Online training packs cost £490.
The JCCP has informed the All-Party Parliamentary Group for Beauty and Safety about this inappropriate and potentially harmful service.
Equally concerning are aesthetic practitioner support groups on Facebook. In these groups, prescriptions for POMs are openly touted without restriction and with no evidence offered that the Medicines Act 1973 is being observed.
If you share the JCCP's concerns and have suspicions about unsafe and unacceptable practice at any point, the safe course is to ask for evidence that the person is on the JCCP Register. This is sure proof that an individual is qualified and safe to treat.