Do I need to be registered in Scotland for BOTOX®, Dermal Fillers and other non-surgical cosmetic procedures?
The Scottish market is not subject to the same regulation (or lack of) as the UK and from 2017, new rules will apply.
HIS Registration Required From 2017
From 1 April 2017 all independent clinics in Scotland are required to be registered with Healthcare Improvement Scotland (HIS).
HIS is the regulator for independent hospitals, hospices, and clinics based in Scotland. An independent healthcare provider is a clinic which is not part of a hospital which has a medical practitioner, nurse, dentist or midwife providing a service not as part of NHS Scotland.
This means that if you’re a medical practitioner, you and your clinic will need to be registered with HIS if you want to carry out treatments like Dermal Fillers and Botulinum Toxins. Without registration, you could be risking your licence to practice.
Interestingly non-surgical cosmetic procedures being provided by beauticians or beauty therapists do not count as part of the definition of an independent clinic and are therefore not required to register. This differs to the position in England where the managed voluntary register of the JCCP will provide a pathway for non-medical practitioners such as beauticians to undertake qualifications from Level 4 to Level 7 to formally licence them to carry out treatments such as BOTOX® and Dermal Fillers.
Lee Cottrill, Business Development Director for SkinViva Training explains that:
“Regulation is a bold move by the Scottish government aimed to improve patient outcomes and ensure practitioners of independent healthcare clinics operate to strict standards.
“I’ve no doubt that this represents a big shake-up for providers of non-surgical cosmetic interventions such BOTOX® and Dermal Fillers who in the past have been free to operate without independent monitoring.
“Ethical and educated practitioners acting in the best interests of their patients should have nothing to fear however and although it will be an initial mountain to climb to put in the initial preparation for their businesses, it will lead to a more robust and well-reputed market in the long run, which can only be a good thing”
The role of HIS in cosmetic procedures
The scope of Healthcare Improvement Scotland is to regulate the below three categories of procedures for non-NHS (Scotland) independent clinics:
- Major surgical procedures (definition includes cutting open the body and may include removal of tissue eg breast surgery, liposuction. General anaesthesia or sedation. Involved a 2nd Practitioner to manage/monitor anaesthetic. Medium to high risk)
- Minor surgical procedures (definition includes invasive techniques with permanent results but usually local anaesthetic or sometimes sedation. Lower risk procedures eg thread lifts, mole removals. Patient can leave clinic within 1 hour)
- Non-surgical treatment (low risk and usually semi-permanent eg certain Dermal Fillers or temporary results eg Botulinum Toxins. Sedation not required)
The move represents a major change to regulate non-surgical treatments such as Botulinum Toxins and Dermal Fillers and the independent practitioners and clinics who offer them.
Implications for Beauticians
The fact that the remit does not encompass non-surgical cosmetic procedures being provided by beauticians or beauty therapists has caused some surprise and concern, as reported in the The Herald.
The Scottish government is hoping to solve the issue of unregulated hairdressers and beauty therapists in phase 2 of the regulation and a Scottish Government spokesman has confirmed that a group has been set up to investigate the work of non-healthcare professionals and report to Scottish Ministers in due course.
Implications for UK Regulation?
Scotland has set a precedent for the UK with England and Wales so far not showing signs of introducing regulation for non-surgical cosmetic treatments.
From January 2018, England will have its own Joint Cosmetic for Cosmetic Practitioners (JCCP) to provide a framework of qualifications and a set of standards for practitioners wanting to offer treatments such as BOTOX®, Dermal Fillers, skin peels, hair restoration, laser and light treatments.
However even before its inception the JCCP has become a hugely controversial entity because it will operate a register for medical professionals and also a register for beauty therapists for the same treatments – a move which is deeply unpopular with medical practitioners. Furthermore, unlike its Scottish counterparts, the JCCP will be a managed voluntary register having no statutory power to regulate independent clinics in England or Wales.
SkinViva Training Manchester
SkinViva Training Ltd offer a range of professional training courses for cosmetic and medical skin treatments.
Their courses in cosmetic treatments directed at suitably qualified and registered medical professionals who wish to learn and build on their skills in delivering these procedures.
See our full list of forthcoming training course dates.
SkinViva Training was established in 2013 by Dr Tim Pearce MBChB BSc (Hons) MRCGP – learn more about us. The SkinViva Training team upholds high standards of clinical training providing a combination of fully-supervised practical experience together with essential theory.
For further information, to discuss which course is right for you, to enquire about availability or to book a training course please call 0161 850 2491, or email firstname.lastname@example.org.