Uncovering an Appalling Decade of Non-Action...

Did you know, In Scotland and across the UK, there are currently no laws to stop members of the public from ANY background from attending a one or two-day course in basic anatomy and facial injectables and then setting up a salon to perform these injectable procedures?

Aesthetic procedures like Botox, dermal fillers, and laser treatments have exploded in popularity in recent years. Social media has fueled the demand for quick beauty fixes and flawless selfies. However, the unregulated aesthetics industry can carry shocking risks.

With little required training or medical oversight, unqualified providers have flooded the aesthetics market. While these treatments may seem minor, products like dermal fillers and neurotoxins are still medical procedures that can cause serious harm if performed incorrectly. 

"Consider: if someone with my nursing background, spanning over two decades, took a single-day course on electrical work, would you trust me to handle the electrical rewiring of your house? Surely not, because it could pose a risk to your safety. So why do we deem it acceptable for just anyone to perform intricate injectable treatments that involve penetrating skin layers and navigating close to delicate facial structures like nerves, arteries, and bones?"

It might come as a surprise to some that injections of botulinum toxin are actually classed as prescription-only medications. This means that unlike reaching out to a general practitioner, obtaining these injections necessitates an in-person face-to-face consultation with a licensed prescriber in the field of medical aesthetics. Only qualified healthcare professionals, including nurses, doctors, dentists, and pharmacists, have the authority to prescribe these treatments. In contrast, individuals from the general public who have merely attended a one or two-day training course are not legally permitted to prescribe them.

The necessity for a direct, in-person face-to-face consultation and the ability to quickly reach your prescriber arise because, should complications like infections occur, individuals without proper medical licensing cannot prescribe the necessary medication to address these issues, regardless of their claims of training. Consequently, those affected—indeed, victims by circumstance—are often left with no choice but to seek assistance from an NHS Accident & Emergency (A&E) department. However, they might be denied treatment there and instructed to go back to the practitioner who administered the procedure resulting in permanent facial disfigurement.

To put it plainly, if you opt for anti-wrinkle treatments (such as Botox) administered by a non-medical person and haven't had an in-person face-to-face consultation beforehand, there's cause for concern. Should the individual providing the injection be unable to divulge the name of their prescribing source, it's likely that the substance used was acquired online and likely imported without authorization from countries like China or Korea. Such products have not been tested or approved by the Medicines and Healthcare products Regulatory Agency (MHRA) for use in the UK. Essentially, there's no telling what's actually in the vial. Typically, a lower price point is a significant indicator of such dubious practices.

It's also important to factor in the insurance coverage aspect for individuals performing injections. Based on discussions with various insurance providers, it is clear that they will not honor claims for injectors who use products without proper licensing for use in the UK. The use of such unauthorized products would effectively invalidate any insurance policy.

The Scottish Public Health Minister stated recently that the aesthetics industry 'is a fast moving industry, and we need to take time to get the regulations robust and correct for the future'.

'Sorry but the future has came and gone a long time ago'

The Scottish Public Health Minister previously articulated that the aesthetics industry evolves swiftly and that establishing strong and appropriate regulations would require careful consideration. Unfortunately, the anticipated reforms have not materialized.

Not one preventable measure has been taken by the Scottish Government in the last decade to protect the public.

The absence of governmental action to protect the public from injury and harm due to this industry represents a grave failure on the part of the Scottish Government. Even after the Keogh Report and Ashton Collins of Save Face highlighted the potential perils and risks associated with untrained individuals (non-medicals) delivering invasive injectable treatments back in 2013—over a decade ago—not one preventable measure has been taken.

The establishment of the Scottish Cosmetic Interventions Expert Group (SCIEG) by the Scottish Government has yet to yield any significant legislative or regulatory outcomes. No consensus has been reached on which entity—be it Environmental Health, Healthcare Improvement Scotland, or HSE—is responsible for tackling this public health issue. Consequently, non-medical persons continue to offer injections in Scotland without any legal deterrent.

Contrary to the warning issued by the Keogh Report, the past eleven years witnessed a surge of non-medicals partaking in brief training sessions on facial aesthetics, only to discover they had been misled about the profitability of such ventures. The majority find themselves entangled in a market saturated with illicit, low-cost imports circumventing MHRA approval, lacking necessary regulation or licensing for UK practices. A rising trend is that these members of the public (non-medical) establish 'aesthetic training schools,' within 3 months of being trained themselves with no medical oversight, perpetuating what amounts to an exploitative cycle resembling a Ponzi scheme.

Scottish Healthcare Professionals working together for Public Safety

The recent jolt of urgency to address this public health crisis stems not from governmental initiative but from us, the concerted efforts of over 300 healthcare professionals who banded together, determined to protect the Scottish public. They have relentlessly lobbied for change, engaging with media outlets like STV and BBC, conducting interviews, rallying MSPs nationwide, using newspapers, freedom of information requests, and social media platforms to catalyze awareness and advocacy.

If any movement happens on this issue it is not down to the concern of the government, it is down to the concern of caring healthcare professionals in Scotland.