NEW legislation to regulate the cosmetic industry for the first time in Scotland is failing to target "bogus" practitioners, doctors have warned.

From April, medical professionals offering non-surgical cosmetic treatments such as Botox, teeth whitening and dermal fillers at private clinics will have to register with a healthcare inspection body.

The move – the first phase of regulation – has been welcomed as a step forward in cracking down on industry where no training or expertise is required to offer procedures, despite a huge rise in popularity in recent years.

But Dr Simon Ravichandran, the president and founder of the Association of Scottish Aesthetic Practitioners (ASAP), said there were concerns the new measures do not yet extend to any non-medically registered practitioners.

He said: “Our concern is as of 2017, whilst it would become an offence for me or one of my healthcare colleagues to run an independent clinic (without being registered), it would not be an offence for a beauty therapist to run an independent clinic.

“The concern is regarding the phases of introduction of regulation – what we want to do is first of all identify the unscrupulous or bogus practitioners and enforce legislation or create legislation to stop them being able to stop them doing what they are doing.

“Then you can concentrate on the people who have already got some degree of regulation through governing bodies.

“Doctors are registered with the General Medical Council for example, so we already have a regulatory authority to whom we can be referred if there is a concern or a problem or a complaint. This is overwhelmingly the wrong way round.”

Under the new regulations, medical professionals will have to register independent cosmetic clinics with Healthcare Improvement Scotland (HIS) by April next year and will then be subject to regular inspections.

Regulation of other groups of practitioners will be phased in until a later date, following recommendations issued by the Scottish Cosmetic Interventions Expert Group last year.

Ravichandran, who trained as an ear, nose and throat surgeon and runs private aesthetic medicine clinic Clinetix in Glasgow, said he would like to see the introduction of mandatory basic level qualifications for anyone offering cosmetic treatments,

“Inspecting the clinics is a great first step, but we need to look at an educational requirement or a training requirement for the practitioners doing this,” he said.

“Having a medical, nursing or dental degree is not a qualification to do these treatments and going on an unaccredited half-day or full-day training course again does not give someone the skills and competencies to perform these treatments safely and effectively.”

Ken Stewart, consultant plastic surgeon and member of the British Association of Aesthetic Plastic Surgeons, said the regulation was a welcome step forward, but it remained to be seen whether it will go far enough.

He added: “Without doubt it is long overdue, the cosmetic surgery industry is entirely unregulated and entirely unscrupulous in some quarters of the industry and the public need more protection.”

A spokesman for Healthcare Improvement Scotland said: “The focus of regulation will be on ensuring safe, effective and high-quality care for users of independent clinics across Scotland. Where appropriate, regulation and inspection will be used to drive up the standard of care in Scotland to the benefit of patients and the public.”

A spokeswoman for the Scottish Government said: “This new legislation will ensure safe and high quality care for those accessing cosmetic treatments at independent clinics across Scotland.

“The phased approach to regulation was recommended by the Cosmetic Interventions Expert Group, set up by Scottish ministers. It was found a phased approach would balance the need for consumer protection and minimise regulatory burden. Phase one is intended to minimise the risk to consumers by tackling the high-profile and more complex procedures, which would be undertaken by healthcare professionals listed under the regulation.”


WHEN Victoria – who is in her twenties and wants to remain anonymous – decided to have some cheek fillers to “freshen” her face, she was impressed by the appearance of the clinic she went to.

But when the treatment triggered an infection she found the clinician who had injected the filler was unsure about how to treat it. She had to take strong antibiotics for weeks and has now been left with facial scarring.

She said: “I went to get cheek fillers because I have had three kids and under my eyes I felt I looked quite tired.

“When I first got them in and one side was perfect, the other side was kind of hard, a tiny hard lump and something just didn’t feel right. I went back to the clinician who said it was just the filler still to soften and it would be fine.

“She said she would put more filler in it – but it turns out I actually had an active infection, so she then injected into an active infection.”

Victoria said despite the infection then getting worse, the clinician only suggested taking mild antibiotics. Three weeks later, after repeated visits she was finally given stronger antibiotics – but by that time she had lost confidence in her advice and sought a second opinion at Clinetix.

“They were the right antibiotics, but she had given me them weeks too late,” she said. “I had to have about 8-10mls of pus drawn out of my cheek with needles.

“I am still on antibiotics and this has been going on for weeks and weeks. I have been left with a scar where the soft tissue infection has eaten away my own collagen in my cheek so the cheek is all indented now and I need to get that filled up.

“I really hope they do clampdown on the industry with more regulation. You think by going to someone that has their own clinic – it is a beautiful clinic as well – she must be really good.

“I don’t want anyone else to go through this – it has been an absolute nightmare for weeks.”