Cosmetic procedures: the supply of medicines to safeguard consumer health and wellbeing

With the advent of a licensing scheme arises the obligation to enable practice that is both safe and legal. A long-standing concern of non-medical independent prescribers, associations and organisations—including the Joint Council of Cosmetic Practitioners (JCCP)—relates to the challenges faced by nurses and other non-medical prescribers. Striving to find a balance between assuring the safety of patients and working within the confines of legislation when faced with urgent response scenarios is not easy. The JCCP is of the opinion that amendment is required for current legislation to enable non-medical independent prescribers to respond safely and effectively to emergency situations that might arise during clinical practice.

Instruments within the Human Medicines Regulations (2012) in England permit medical prescribers—doctors and dentists—to obtain prescription medicines on a ‘wholesale’ basis, where the medicines have not been dispensed to a named patient by a pharmacist. This provides the medical prescriber with an immediate supply of a medicine, from which they can prescribe and dispense or order the same to be carried out. It is a mechanism that facilitates appropriate patient access to medicines in a manner that is governed by the professional regulator. The medical prescriber is not permitted to pass on these wholesale supplies to others, but non-medical prescribers within the same practice may access these medicines to prescribe and dispense. Again, this activity is governed by the relevant professional regulator.