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The recent Times investigation and subsequent reported investigation by the MHRA on the use of unlicensed botulinum toxin in the UK is something that is sorely needed in a sector that is unregulated. A long time has elapsed since the Keogh Report in 2013 and it appears that very little has changed since this “toothbrush” comment report; a cynical viewpoint is that the regulated have become more regulated, with a widening gap and the unregulated being able to continue in an unregulated manner.

The recent investigation did not reveal anything new – a lot of practitioners have been aware and have tried to report the use of unlicensed drug use in aesthetics with no avail. The regulatory bodies appear to have “no teeth” to deal with the unregulated practitioner; there needs to be a standard that applies to anyone involved in performing these procedures, i.e. universal regulation within the UK that requires anyone performing the procedures to have attained a specified standard of training and be overseen by an unified regulatory body. The concept of regulating the regulated does not appear to be working. A unified approach by medical specialist bodies including dental, nursing and medical could be considered to bring medical practitioners together with a common standard and practice, combined with stronger robust mechanisms to deal with unregulated practices.

Apart from the breakdown in the regulations by unlicensed practitioners the investigation also exposed some other aspects of aesthetics that should also be considered. The majority of the clients / “patients” who attended the practitioners became aware due to a heavy social media presence. The Advertising Standards Authority has drawn a code of conduct regarding the use of social media in relation to botulinum toxin, however, a quick perusal through social media clearly shows open breaches of this by both regulated and unregulated practitioners. Once more, the regulatory bodies appear to be powerless to monitor and sanction these actions.

In a time where morals, ethics and integrity sometimes appear to be in short supply, the fact that some practitioners “did not know” that a product was unlicensed is quite profound. One of the problems is the fact that many non-surgical minimally invasive procedures are treated like supermarket commodities – readily available on the high street and administered in non-clinical areas including mobile services, which encourages a culture of lack of clinical standards and a drive to reduce prices to attract more clients. Many practitioners in the sector and those looking to enter the sector see the procedures as purely technical in delivery and many training programmes concentrate on “training” practitioners to just deliver the treatment. There are few that provide insight into the morals and ethics of aesthetics – something that is sorely required in this sector.

The recent investigations may spur the regulatory bodies, public and practitioners to review the current practices, reflect on possible actions to take and go further than the 2013 Keogh Report.

Dalvi Humzah

West Midlands, UK.

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