Practitioners' First Choice
Practitioners' First Choice

Did Health Improvement Scotland’s New Filler Policy Miss the Mark?

IG @dr.malaika.clinics

The industry has once again been up in arms the last month as Healthcare Improvement Scotland (HIS) brought out a new regulation seemingly overnight. The new regulation stipulates that non-prescribing healthcare professionals can no longer inject dermal fillers without a prescriber present. Now I should probably point out that this is something I have long said should be standard practice anyway. Although dermal fillers are themselves not prescription only medications (POMs), the emergency drugs, needed in case something doesn’t quite go to plan, are POMs, and therefore a prescriber should at the very least be available on site in case of emergencies.

However, as with all regulations in Scotland, only medical injectors are affected; beauticians and other non medical practitioners can continue to inject dermal fillers without a prescriber present, which begs the question, if this was done to keep patients safe, why was it not introduced across the board? Or is this a subtle hint from HIS that only prescribers should be deemed qualified, and therefore safe, enough to carry out aesthetics treatments?

Once again an example of overregulation of the already regulated; not entirely a move in the right direction unfortunately.

IG @drsam.aesthetics

I’ve long said that dermal fillers should be made prescription only medicines (POMs) but we have an inconsistent situation in Scotland whereby fillers can be bought by anyone, who can administer them is regulated only if you’re a Healthcare Professional (HCP), yet dealing with emergent complications can only be dealt with by a prescriber.

If you haven’t got a prescriber available to deal with a vascular occlusion, I can’t see how you can be safe, but there needs to be consistency applied to both HCPs and non-HCPs. HIS seem to have done what the MHRA should have by attempting to make fillers effectively into POMs but their rules only apply to HCPs whilst non-HCPs continue to inject freely. 

Unfortunately, the UK has it completely back to front when it comes to regulating aesthetics. Rather than taking a bottom-up approach and trying to control the more dangerous, non-HCP practitioners who are poorly trained and who practise without oversight, HIS and CQC can only create obstacles for those already regulated by professional bodies.

Bringing in regulations overnight without giving practitioners time to adapt, potentially risking livelihoods during a cost of living crisis and before Christmas is extremely tone deaf. We’ve got a crazy situation where HCPs may consider handing back their professional registrations to practise freely without HIS oversight.


One Response

  1. What a great topic! I have business partners in Scotland and this has been a topic of conversation recently! Yet again more regulation for the already regulated and no changes for the ones who have no regulation.. it almost feels at times that the medics are being punished for being medics ha ha crazy world

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