Well it was to be expected!
Hot on the heels of our recent government’s decision that it was okay for anyone in England* who wants to have a go at burning your face off with a CO2 Laser or IPL machine to do so with impunity, along comes cosmetic injectables in the hands of non-medics.
(*Ironically this decision also implies that lasers and IPL are more dangerous in the hands of the Welsh where regulation remains!)
The former and current government’s failure to properly regulate the cosmetic injectable market means that coming to a High Street near you soon could be the local barmaid offering “Botox with a Beer” or perhaps your postie, (he has just had his pension cut after all) could also give you a quick injection along with your letters to boost their incomes. Or maybe this could be the new occupation for all those civil servants the government are about to lay off!
How, you may ask, could this be possible? Well, during a round of internet searching I discovered the following site www.academyofcosmetics.co.uk offering Botox® and dermal filler training to ‘non-medical personnel’.
They state in their home page advertising:
“Despite what you may have heard anyone, even those without prior medical knowledge are able to administer these injections after undertaking a BOTOX® training course or dermal filler training course. We will now explain why.
Medicines and Healthcare products Regulatory Agency (MHRA), is a Government agency who are responsibility for standards of safety, quality and performance. They regulate all aspects of medicines and concur with the DOH that BOTOX® and other injectable medicines may be:
a. self administered
b. administered by an appropriate practitioner
c. administered by anyone acting in accordance with the directions of an appropriate practitioner.
This means that legally anyone can give an injection as long as they are directed to do so by a prescriber before it is administered. The reason that doctors, dentists and nurses have routinely given these in the past is not only due to their knowledge and experience but also as they have been the only practitioner that has been able to obtain insurance to practice.
This is changing rapidly. Non-medical personnel, for example phlebotomists, dental nurses, ODPs, pharmacists, health care assistants, beauty therapists, semi-permanent make-up artists and tattooists are now being offered insurance by well known insurance companies.”
All that you need to do to attend one of their courses it to pass a Level 3 Anatomy and Physiology course which they are about to start offering as well, but which can also be sourced from a multitude of correspondence course providers nationwide.
Before injecting real people on the day you start off with empty syringes and dummies to practice on, so you can supposedly master the techniques. The good news folks is that they do not just give out certificates of competency to anyone, oh no, you actually have to inject 4 people on the day to prove that you are competent to inject – (despite the fact the results of botulinum toxins take up to 2 weeks so adverse effects would not show on the day!!) If you inject less than 4 people you only get a certificate of attendance, but that’s okay, you can still inject people whilst you build up your portfolio of evidence to support your upgrade to a certificate of competence, all whilst not insured, but that’s alright as the consent form you will use states that! (Well that’s me totally reassured then!)
They do state that they cannot supply you with botulinum toxin as you need to have a practitioner write a prescription, but they are able to supply you with practitioners that will do this so you can get the product and inject away!
The really good news though, that will please the GMC, NMC, MHRA and surely the new IHAS Register for Cosmetic Injectable Providers (Quality Assurance Mark) Scheme is that: “...only doctors and nurses have the necessary skills to train you in basic medicine and drug interactions which is included in our course agenda.”; and “...you can be assured that you will be taught by the very best in the industry”.
SURELY THE REASON THAT ONLY DOCTORS AND NURSES HAVE THE NECESSARY SKILLS TO TRAIN YOU IS BECAUSE ONLY DOCTORS AND NURSES HAVE THE NECESSARY SKILLS TO INJECT!
In the testimonials section of their site*, they have a diabetic delegate explaining that he felt confident attending the course and now injecting others as he has injected himself everyday for the last 5 years with insulin!!
He booked on to the dermal filler course and took his wife and 4 friends as models and they then forced him to do the Botox® course, but luckily the Academy was happy for him to enrol on this a few weeks later, (no surprise there then, I’m sure they were happy to take his £1,300 too!) He continues to explain how word is spreading and that he injects friends of friends every moth now.
A beauty therapist also comments: “Now I am trained I can safely say that I will be working with a doctor who will make sure I inject in the way the law says I should. Thanks The Academy of Cosmetic Training."
Isn’t that great? This is the same “law” that says it is illegal for her to inject a dog but a human is fine!
Another delegate, a tattoo artist explained how: “So far it has fitted in perfectly with my business of body piercing and tattooing. I use needles every day and it is a different technique to what I was used to but I soon got the hang of it.”
Do you think that as I once sewed a button on my shirt with a needle, they will let me have a go!? It’s a bit of a different technique but I am sure I will get the hang of it too!!
The questions that really need answering are:
- WHO IS INSURING THESE PEOPLE?
- WHO IS DOING THE PRESCRIBING?
- WHO IS SUPPLYING THESE PEOPLE? (There are only 3 toxin manufacturers currently licensed - surely they can keep a better eye on their product than this?!)
- AND WHO IS TRAINING THEM?
Well me being me and wanting answers I called them, mystery shopper style!
The insurers are Cathedral Associates Limited – if any of you clinics out there are insured by them, it might be worth cancelling your policy very soon as the premiums could be about to go up as all the mistakes come in from the non-medics! (This is also the same insurance firm that we highlighted as offering insurance for beauty therapists who completed a dermal filler course with James McGrath back in our April 2007 feature article - Beauticians Offering Cosmetic Injectables & Peels.)
Details of the training provided were very vague but it I was given the name of a known RGN from the North West who was involved, but there are most certainly others so I will not name and shame her alone.
A doctor is doing the prescribing, but they refused to give me the name(s), stating their reason being that this encourages people to approach the doctor direct, rather than going through the Academy, something which the doctor(s) does(do) not appreciate. So, MHRA and GMC, now it is your job to continue that part of the investigation as they will prescribe without seeing the client; is that legal for cosmetic procedures I wonder?!?
The product supplied is BOTOX®. Now I know Allergan will come out with the usual “...we cannot control where our product goes and there are several pharmacies that could be supplying it so it is not our fault” excuse but in fact at last check there are only two pharmacies supplying Botox®, namely Health Xchange and Med-fx or you can source from Allergan direct. I would suggest that Allergan do their investigating and stop this, otherwise I am sure the industry will vote with their feet; there are 2 other good toxins out there in Dysport®/Azzalure® and Xeomin®/Bocouture®. It shouldn’t be that hard to see who has been buying that much more all of a sudden!
Finding out who exactly is training delegates was a little trickier; and unfortunately this information was not forthcoming.
Just to really worry you all though, 17 out of their next 18 courses, which all take place before the end of October 2010 in three locations across the country are fully booked – maybe after all, it really is the government’s way of lowering the dole queue!
This to me goes to demonstrate the ridiculous nature of the current legislative situation of Medical Aesthetics, how can the government, the GMC, the NMC, the MHRA and let’s be honest, the Industry allow this to keep happening.
*Since writing this blog and contacting the company via a mystery shopper telephone call the company’s website has been changed and certain information subsequently removed.
We saved copies of the website during our investigation and screen shots of the FAQs and testimonials will be available via the September Edition of our Gold Members Industry Newsletter. Medical professionals interested in attending courses run by reputable training companies can visit this Cosmetic Training Directory.