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BACN to update Code of Conduct on the training of beauty therapists

On the 7th and 8th November 2019, at the BACN Autumn Aesthetic Conference, a motion was proposed that Regulated Healthcare Professionals should not train or prescribe for Beauty Therapists/Lay people in injectable cosmetic treatment such as Dermal Fillers and Botulinum Toxins.

The statement by Sharon Bennett, BACN Chair, and agreed by the BACN Board was delivered at the conference:

This question raised on the BACN  Facebook Forum this month culminated in a consensus of disapproval in the training and prescribing for these groups.

We have seen a growing number of Beauty Therapists delivering the most invasive aesthetic procedures to the public, including non-surgical rhinoplasty, jaw and facial sculpting, fat dissolving with unlicensed products, large volume lip fillers and so on. The complications in cosmetic treatments are rising with hundreds of cases of adverse events, the public exposed to an inability to be cared for medically by this group and those training them not accountable. The public are often subject to ghosting, blocking and intimidation should they complain, and the medical profession are increasingly required to pick up and help, often out of goodwill.

Let us not forget the principles of the NMC Code which require us to act, at all times, within the patients’ best interest and be able to demonstrate our own competency for all we do but also the competency to those we delegate to. 

One could postulate that those training someone else in healthcare is akin to delegating a task, and that those training others therefore must be  responsible in ensuring that the training  meets the NMC  delegation requirements.

The same applies to prescribing for others and the delegation of the administration of medicines.

There is now no ambiguity relating to remote prescribing of cosmetic medicines, including toxins, and the NMC has issued the following , “ All prescribers must take individual responsibility for their prescribing decisions and should recognise that there are certain areas of practice where remote prescribing is unlikely to be suitable, for example when prescribing medicines likely to be subject to misuse or abuse, or injectable cosmetic treatments”(NMC 2019)

Delegation

According to the NMC, Delegation is defined as the transfer, to a competent individual, of the authority to perform a specific task in a specified situation. The NMC have set out expectations of people on their register and that the delegation of tasks will be in the other persons scope of practice of competence, and they fully understand what is being asked of them. They must also ensure that they ( whoever they delegate to) are adequately supervised and supported so they can provide safe and compassionate care, and that they meet the required standard.

There are many instances within the NHS where Healthcare assistants (HCA),  are trained to carry out specified tasks and support the medical team, and they become an invaluable team member. Perhaps an HCA who has been trained to do venepuncture and provide patients with information of their treatment or a sexual health HCA who takes an initial consultation and initial diagnostics. The HCA will work within a team and will be answerable to a medical lead.  At no point does the HCA take on autonomous care for the patient. The patient is safeguarded.

Whilst the task of injecting a botulinum toxin or a dermal filler ( implant) at its most basic level can be taught relatively easily, a much wider knowledge and clinical acumen is required. The tick box consultation method in medicine does not work if the answers to the questions are not clearly understood and acted upon. Our own patients may present with a medical condition or medications and our clinical judgement,  scrutiny and reasoning will come into play when we consider and plan their treatment, and we may decide not to treat, or we may refer.  A qualified nurse is furnished with competency in multiple clinical skillsets, judgement, critical thinking and evaluation. A beauty therapist (or similar)  is not and the phrase “competently incompetent” is well suited. 

The training of a Beauty Therapist/Lay person who has : No medical qualification, No clinical knowledge or acumen, No pathway or requirement to demonstrate competency, Not required to evidence or show accountability, Cannot consult or consent adequately as the clinical knowledge is absent, Cannot prescribe and therefore manage complications, Not part of a multi -disciplinary team, Not answerable or accountable for their actions…. must surely conflict with the Code where maintaining patient safety is a priority. 

We have no doubt that the practice of teaching the Unregulated beauty sector or lay people,  to administer cosmetic injectable  treatments is contrary to the NMC Code of Conduct.

References

NMC 2019

https://www.nmc.org.uk/standards/standards-for-post-registration/standards-for-prescribers/useful-information-for-prescribers/

The motion has also been supported by the British College of Aesthetic Medicine (BCAM) and the Aesthetics Clinical Advisory Board.

The Aesthetics Clinical Advisory Board, of which BACN Chair Sharon Bennett is a member, also agrees with the BACN’s motion.

Following the motion passing at the conference, the Code of Conduct will be updated.

More information can be found on the Aesthetics Journal website by clicking here.

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