Needles at Dawn! Beauty Therapists Challenge IHAS Over Who Should be Allowed to Inject Botox & Dermal Fillers

Posted on the 15 March 2011 at 11:55

This week has seen the gauntlet well and truly laid down between the aesthetic (beauty) therapists and the medical fraternity (doctors, dentists and nurses) when it comes to who should and shouldn’t be allowed to inject the general public with cosmetic injectable products including dermal fillers and botulinum toxins. The debate has now been thrown wide open.

The Cosmetic Treatments and Injectables Association (CTIA), formed this month by its Chairman Molly Hanson-Steel, has openly set out to challenge the Independent Healthcare Advisory Services (IHAS) and its Treatments You Can Trust Register which excludes practitioners who aren’t doctors, dentists or registered nurses from its government backed quality assurance accreditation scheme for cosmetic injectable providers.

Having been involved in the industry since the launch of Botox® in 1994, I've been fortunate enough to have watched the cosmetic injectable market evolve and develop and to listen to all the arguments from practitioners with different backgrounds who want to generate an income from this evolving market segment. Plastic surgeons and dermatologists initially were concerned, (and some still are), with doctors from other specialities being involved in cosmetic injectables, and some doctors are not supportive of dentists or nurse prescribers using these treatments. There are also heated debates going on amongst nurses as to whether non-nurse prescribers should be involved in injectable cosmetics, with the NMC certainly not being supportive of non-independent nurse prescribers using prescription cosmetic injectables.

However, in recent years the debate has, in my opinion, entered an entirely different level with some beauty therapists now trying to validate their claims to the use of a prescription medicine (botulinum toxin) and dermal fillers for cosmetic rejuvenation.

We’ve highlighted our opinion of this in several past blog posts, including The Mad, Mad World of Medical Aesthetics and Botox Training For NonMedics-Surely Not in the UK?! where training courses have been offered to beauty therapists and other non-medically qualified people, and although NOT ONE of the major suppliers and manufacturers of these products support the use of their products by non-medically qualified practitioners, it appears that they are either powerless in stopping the supply of their brands to these people (available through various routes), or they just don’t care where their product ends up, as long as someone pays for it!; (which I hope isn’t true!)

So, you may wonder, if NOT ONE of the manufacturers, suppliers or distributors in the UK PUBLICLY SUPPORT the use of their products by ANY non-medically qualified person, why are beauty therapists so vociferous in persisting with their case for use of these products?

Speaking about the formation of CTIA, Molly Hanson-Steel said; “More and more bad press about injectable administrators is hitting the headlines because of malpractice and/or incompetent procedures. The perception is that the Cosmetic Industry Practitioners are the perpetrators of this bad practice when in reality this is not the truth. The CTIA intend to provide a clear structure to raise safe practice and standards in the cosmetic injectables industry. We will promote quality assurance through inspection, training and external audit. Our procedures will result in promoting safer practices for the client and awareness of our sector to the public. We do not agree with a registration system without inspection”.

Hence, an inspectorate body has also been set up known as the Cosmetic Dermal Botulinum & Fillers Inspectorate (cdBAFI). They state on their website that; “we do not feel that if you are a dentist, doctor or nurse that automatically enables you to perform this type of non-surgical cosmetic treatment at the exclusion of the cosmetic industry professionals practicing in this area.  We want ALL practitioners inspected to enable the consumer a choice.”

Stuart Naisbett, Director of Inspection at cdBAFI also said recently; “We created the Inspectorate on behalf of the consumer...not the medical profession or the Cosmetic Industry. We are an independent Inspectorate that wants to assure the consumer that the injectables practitioner that they choose to perform their treatment has been inspected to the same industry standard.”

cdBAFI are working with the CTIA to introduce new training standards for cosmetic injectables and also claim that they would be happy to also work with IHAS to introduce a generic standard for all. They intend to evaluate both the people and the organisations involved in the provision of cosmetic injectables.

To further highlight their cause, CTIA along with the British Association of Beauty Therapy & Cosmetology (BABTAC) and cdBAFI, formed a delegation to visit the Department of Health and meet with the current Health Minister, Simon Burns regarding the regulation of cosmetic injectable treatments. In particular they wanted to discuss the implied exclusion of beauty therapists and other cosmetic industry participants from practicing within this marketplace due to their exclusion from the IHAS shared regulation scheme, which was granted funds from the previous government for the development and promotion to the public of a register of accredited cosmetic injectable providers.

The delegation is said to have highlighted its concerns to the Minister about what they believe is an unlevel playing field in the area of non-surgical injectable beauty treatments and outlined the fact that the public should be made aware that they are training up dentists, nurses and doctors on the NHS to work in the private health care sector offering non-surgical beauty treatments. A cynical argument indeed.

We would love to know what you think, so please either complete our simple poll which asks whether you think beauty therapists should be using cosmetic injectables and/or feel free to add a few words to the debate by scrolling down to the comment box below.

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Blog Comment(s) [51]

I think that Botox and Dermal fillers should only be administered by an Aesthetic Doctor, NOT beauty therapists or in fact doctors that do not have adequate training in Aesthetics.
It is bad enough that the CQC is now allowing any Tom, Dick or harry to perform laser treatments without adding Botox to the list.

Kelly Harding

"Almost all absurdity of conduct arises from the imitation of those whom we cannot hope to resemble.”
Samuel Johnson

Dr Patrick J. Treacy |

Thanks for doing this Ron. I started writing a similar blog today, however when I realised how long it was becoming, I lost the will to live and abandoned it - so I am glad that you managed to see it to the end.

The problem with this issue is that provided the Beauty Therapist gets the services of a doctor or dentist (which we all know they will) to sign the scripts for them, there is nothing illegal about administering Botox and because dermal fillers are medical devices (and so fall outside the Medicines Act 1968 and associated regulations) there is quite simply nothing to stop them doing treatments provided that the patient is aware that they are not doctors/dentists/nurses.

In theory anyone off the street can "pop in" and do a coronary artery bypass graft operation provided that the patient consents (so there is no assault/battery) and that the person carrying out the procedure does not mislead the patient in anyway as to their skill, experience or qualifications (there by not contravening the statutes which protect the various professions (eg Medical Act 1983).

We know only too well that there will be no government support for any form of opposition to this organisation. As witnessed by the deceitful manipulation practised by the DoH in relation to the deregulation of lasers and IPL systems over the last 2 years. They promised dialogue, discussion and that they would become involved while all the time they simply stalled until there was no time to arrange any appropriate form of regulation to replace the CSA2000. It is only now that everyone is waking up to the impact of this in terms of the vastly increasing number of incidents and accidents and the fact that chinese laser and IPL systems are now appearing on every street corner and charging a fraction of the cost of a treatment carried out by a reputable system because a) they are ineffective and b) they only cost £1000 including delivery from Beijing. Even the reputable laser manufacturers who initially rubbed their hand with glee at deregulation are now beginning to pause for thought at the stagnation of the domestic market.

What awaits us?

There will be some murmurs of discontent from qualified practitioners and may be even a campaign. Only a spate of deaths or severe facial disfigurement of eminent celebs could get sufficient media interest to raise this to public consciousness in order to embarrass the government into changing the law.

I assure you, nothing will change the eventual outcome.

I am thinking of putting my name down for an NVQ 3 Beauty Therapy so I can become a real doctor!

Dr Philip Dobson |

As a practising beauty therapist of over 15 years, I have read some of the derisive remarks and 'felt' the negtive attitude towards my profession on this blog.
Not all of us are irresponsible, or presume to have the knowledge of 'real doctors'!
Is it not fair to say that a bricklayer can have the IQ of a professor but chooses to do a job that he likes rather than loathes?Its a personal choice, right?!
Personally,My point is that any kind of injectables should be left to the medical practitioners. But, I would also like to see the medical profession offer some respect to beauty therapists and work with us....the snotty remark about NVQ 3 was uncalled for. Just because you have the title of Doctor or nurse, does not mean you are a god!Or infallible!
I know some nurses who offer injectables and frankly, their proffessional practice is, let the debate rage. There are faults on both sides.

sarah jayne

Thanks for your comments Sarah-Jayne - you are, of course right, there are "good" and "not so good" professionals in every speciality. This blog is not meant, in any way, to decry beauty therapy professionals. I have seen some excellent therapists happily working alongside medical professionals in aesthetic clinics, and they are seen as valued members of the team who often possess a different, but complementary skillset to help make the business more successful. Indeed, my own daughter is currently training to be a beauty therapist and I will encourage her to fully explore all of the many different treatments - from IPL to laser; electrolysis to semi-permanent make-up that are now available to her. However, having seen some medical professionals over the years struggle to manage the rare, but occasional problems associated with the use of toxins and fillers - I truly believe that you need not only to be medically qualified, but also have MULTIPLE training (not just one course) and, preferably a form of apprenticeship to learn how to use these treatments safely and effectively. Unfortunately, as there is also no legislation around training, there are some medically qualified professionals operating in this market who maybe shouldn't be.

Ron Myers |

Given the total apathy of the GMC, NMC and MHRA to curb illegal practises amongst some doctors and nurses within the aesthetic industry then I think that we will all be waiting for a long time for anyone to tackle the subject of beauticians working in aesthetics. The beauticians are not working illegally, as Phil quite rightly says, so they are actually in a better position legally than hundreds of nurses!
The governing bodies are aware that patient details are used fraudulently ( without their knowledge) to obtain drugs that are then used by nurses as stock cupboard items. Using the drugs on patients other than the named patient is classed as theft. Theft is a criminal act. Everyone knows that this is happening and it is accepted as normal! The governing bodies just turn a blind eye as do the pharmaceutical companies. Any industry that accepts criminal activity as normal cannot possibly object to beauty therapists who are not actually doing anything illegal at all.....
If the industry will not act to stamp out illegal practises amongst its doctors, dentists and nurses then it cannot possibly do anything to oppose individuals who are working within the law....

Mai Bentley

I find that most beauty therapist are very sensible and practice within their comfort level and competence. I would like to know what proportion of beauty therapists actually want to offer injectables and support this organisations agenda. Being aware of potential complications I do think that only medical professionals with suitable training should carry out these treatments. Yes, some of these procedures are relatively simple and straightforward but many are complex and require medical, surgical and aesthetic skill and experience. Ofcourse any complications can be disastrous.

Dr Sanjay Gheyi |

I think it should be an even playing field. Although I am an RGN, I do not think I should be able to go on a one day course (or a 2 day and case study) and be really good and safe.

I would really say the same about the Doctors I work with.

If beauty therapists and others are to take all the Anaphylactic Management tests and all the other things I would say they would have a head start on most of the other nurses I know. My daughter who is a therapist knows far more about the facial muscles than me, and I know she would be (currently) superior.

Kind regards


Jan Stains

I hope that most dentists, nurses and beauticians are aware that under the new European CEN/TC 403 guidelines they will probably not be allowed by standardization regulations to inject either Botox or Dermal fillers. This has happened already in some European countries (such as France) and Austria is presently moving to make it mandatory across the whole continent. In fact the UK is unique amongst European countries that this now happens. There are also going to be mandatory specific regulations for minor operation rooms where these procedures can happen so most of this discussion above may be of little relevance within a short time. I would stress it is not as yet at legislation level but in view of this developing situation the British Government will certainly not want to be seen to be endorsing the very problem that other European nations are trying to eliminate.
I totally agree there are many wonderful aestheticians out there and we were amongst the first European clinics to integrate this level of professional personnel extremely successfully as far back as 2001. There is little doubt medical aestheticians interact less formally with clients than medical personnel and consequently achieve much higher product target sales and have a closer personnel relationship with our patients. My concern is that the new CEN/TC 403 guidelines will technically ban therapists from all RF work, vascular IPL, most peels and almost everything except depilatory lasers. My word of advice would be to fight this corner rather than taking on a new procedure list that people with 'perceived' higher qualifications ( including some doctors) will certainly struggle to hold on to.

Dr Patrick J. Treacy |

I don't think people are trying to demean beauty therapists by suggesting that only appropriately trained doctors, dentists or nurses should administer Botox or injectable fillers.
It isn’t just a question of can they perform a specific task, but more one of are they trained to respond to any problems which occur as a result of that task.
Medically trained practitioners should be able to respond to problems that might occur (and should also make sure they are properly trained in whatever procedures they intend to carry out).
I am sure that a beauty therapist would be able to inject Botox into someone in the correct place. But this isn't the point. To have an aesthetic procedure done properly demands proper training and a thorough understanding of the anatomy and physiology of the face, it isn't a matter of injecting the Botox into the right place. Every client has different requirements and the skill in aesthetics is in assessing what the requirements are and knowing how to fulfil them. If it was just a matter of injecting into a fixed set of points we might as well just flog the 'do-it-yourself' Botox kits available over the Internet.
As a profession we should be striving to raise our standards (for training and audit) and not to dumb them down. There are so many detractors out there who are fundamentally opposed to the concept of medical aesthetics that we don't need to help them by adding to their arguments.
Aesthetics is not about saving lives it is about providing a service to enhance someone’s life and as such our clients have high expectations. As a profession we should strive to maintain high standards not only to meet clients expectations but also to make sure that we are credible as a specialty in our own right.

Dr Michael Casapieri

I have been involved with the aesthetic industry for many years, yes I have seen many changes. Being involved with many seminars regarding this subject, one thing has come to light, there is a lot of revenue protecting going on, and its fairly obvious from many of the comments that are being posted, above and below. People are talking about the safety, but you will find that many (a lot) Doctors and nurses are using Botox "of label" against the manufactures advise. One should understand that a nurse (or a doctor in fact!) who has been working in a care home for many years can do a short course, would they be experts in facial anatomy? would they really know what to do apart from the average resuscitation. My local GP, this is no exaggeration is around 24 stone, and can hardly move, I do knot know what he would do.

Hats off is there is anatomy courses and they are teaching a full range of Anaphylactic Management for therapist, but the obvious revenue protection has been noted by many, I am a nurse and have worked with some really sensible people in my time, and some that are not, it may come as a shock that I am batting for the other side, but 7 years ago I trained in advanced beauty, I did learn so many things that were not in nursing, the facial anatomy including. The only way if for people to be separately judged and merited.

All the best

Sally Ann Harvey RGN

Injectibles are invasive medical treatments, no matter what government wants to think for revenue purposes; sticking a needle into someone is invading their personal space quite intimately and should be restricted to persons able to handle ALL of the consequences of injecting injurious substances into live tissue - and that includes the very worst outcomes such as tissue necrosis and anaphylaxis, not just ptosis and granulation.

There is just no equivalence in the relative duty of care between a registered HealthCare Professional and a qualified beauty therapist. When it comes to the worst case, the HCP is liable personally to the extent of having their professional capacity to work withdrawn - even as a result of negligence when they are walking down the street - where the BT can walk away with treatment malpractice carrying no professional sanction. This differential is indicated in the cost of medical indemnity vs beauty insurance, which looks to be about 10/1 which is not to say that beauty providers are 10 times safer but that the cost of settling such claims is about 1/10th the cost of settling a medical negligence claim.

The beauty lobby wants its cake (in delivering cheap treatments with no statutory controls and with limited personal or professional responsibility) and eat it (in claiming equivalence with medical delivery that takes place against a completely different set of onerous and costly regulatory criteria).

All of this is of course a consequence of governments prejudicial belief that cosmetic medical treatments are fundamentally different to other medical treatments and that persons seeking cosmetic care are somehow not worthy of the duty of care applicable to persons seeking other medical treatments. In deregulating (and unregulating) cosmetic medical applications for taxation benefits, government also attempts to absolves itself of inalienable responsibilities in respect of their own duty of care in public health. In allowing any willing cosmetic provider to do what they want to anyone who agrees (whether or not they have consented in any meaningful way), government opens another Pandoras box and who knows what the consequences will be but precedents in banking deregulation don't provide good omens. In any case, government are responsible for this free-for-all and should be held to account when it inevitably goes wrong.

Let us hope that current activity by Medical Bodies represents a standing up to overweening government and its murky agenda. If professional bodies can work together rather than against each other, they might also want to lobby properly for a return of these medical interventions to medical controls rather than trusting to the open market.

Paul Stapleton |

Unfortunately this is primarily an ethical argument rather than a legal one, and Dr Dobson has clearly explained why this is so. The Society of Cosmetic Physicians & Surgeons firmly believes that it is not in the publics best interests to allow non-medical practitioners to inject patients with drugs or medical devices such as dermal fillers. As a result, we do not endorse remote prescribing for botulinum toxins, and as such do not accept any applications for membership from any parties engaged in such practice.

Dr Ravi Jain |

It's absurd that injectable treatments could be carried out by non medical practitioners or therapists. In theory anyone can technically inject a dermal filler after all they are medical devices, however, anaethetics commonly administered along side a lot of these treatments are prescription only preparations as are botulinum toxins let us not forget this. The worry is what happens when a treatment goes wrong, what is your point of action. Having until recently acted as a clinical specialist for one of the major pharmacutical companies I'm only too aware that adverse events do happen, the swift action of the "prescriber" is paramount in damage limitation to that poor individual that has suffered the event. Scientific product knowledge along with the understanding of pharmacokinetics and pharmacodynamics will God forbid if it ever happens ensure the patient gets the best favourable outcome I doubt any therapist no matter how wonderful their chairside manner could do this

Sharon Bailey RN, Clinical Specialist, INP

I agree with many of the comments presented here. This is really not about a turf war - it goes much deeper than that. As you will note, dermatologists, plastic surgeons, cosmetic doctors, dentists, cosmetic nurses truly do agree on this point, as do most sensible beauty therapists I know. There is NO viable reason for beauty therapists to be performing medical procedures when consumers are already widely serviced by qualified medical professionals - purely for profit. This should not fall under the scope of restriction of trade. Beauty therapists should stay within their scope of practice. If they want to inject PRESCRIPTION DRUGS (which is what Botox, Azzalure, BoCouture are), they should be retrained as nurses, dentists or doctors and get qualified. Is it legally authorised for semi permanent makeup artists to give clients an injection of local anaesthetic? Not to my knowledge. It just makes good sense and protects the public. Of course not all injectors who have MDs are good, competent or ethical, however, they are at least presumably "medically trained," which should be the absolute MINIMUM requirement to stick a needle into someone's face where there is a risk of damaging skin, nerves, and other tissues. I attended a spa exhibition in NY recently and was appalled that there were non-medical people teaching other non-medical technicians how to "make $$$" as they put it removing skin tags, moles and other bits. This is a serious matter and I FIRMLY BELIEVE than no individual who is not medically trained and properly licensed should be removing tissue samples of any kind from any person. And how are beauty therapists getting their hands on botox and fillers anyway? Surely big pharma companies are not selling their products directly to them? So what exactly are they injecting and who is giving to them under the radar? I would like to know.

Wendy Lewis

Further to what Mai said above, it is classed as theft when you use a prescribed product on another patient but there are doctors, dentists and beauty therapists doing this also, not just nurses. Beauty therapists are not in a better position nor are they better protected as they are still answerable to the law. They have to adhere to the Medicines Act, they cannot make prescribing decisions and whilst they do not have a governing body looming over their heads threatening to take away their beauty therapy certificate, they do have a Solicitor, Barrister, QC and legal battle waiting to greet them if they do break the law. Simply not knowing about the legal requirements is not a defence.

To state that only doctors should inject is ludicrous. What would happen if this European directive came into force in the UK? Why would a dentist or nurse be deemed as not suitable to inject a dermal filler or botox when they work with syringes in their day job? Would dentists no longer be able to administer LNIs before doing a root canal or apisectomy? Would nurses no longer be able to administer daily injections via SC, IM, ID or IV? The NHS would grind to a halt!

A dentist has extensive knowledge of facial anatomy and undertakes injections continually throughout their daily practice, nurses spend years learning to care for patients across a variety of settings and continually administer medicine to patients. They also have to be sure that the doctor has prescribed the correct dose before they administer it so they have a lot of responsibility. Doctors are taught to diagnose and treat a variety of conditions so all 3 professions are highly suitable to administer treatments. A beauty therapist not once picks up a medicine or syringe in their training, yet they wish to enter into the world of aesthetic medicine. This agency you mention here seems to suggest that beauty therapists are more qualified to inject fillers and botox than medical professionals, with no injectable training at all how is this so?

Does this give the public comfort in knowing that a beauty therapist can do whatever they want until they have a complaint made against them? The public are in safer hands surely when treated by a medical professional as they have knowledge, experience and the threat of their governing body waiting to remove their registration if they put the public at risk or break the law?

Botox can be prescribed and administered off label if it is deemed acceptable by your peers. I think the arguement that medical professionals are prescribing off label is irrelevant as any beauty therapist who injects Botox, xeomin, dysport for cosmetic use is injecting off label also. Where a beauty therapist falls short is the fact that they could train in life support and management of anaphylaxis but they cannot prescribe adrenaline, it would have to be prescribed for each patient they treat as well as being directed to do so. Would they really have a doctor on call to prescribe in an emergency situation?

A common problem we see in this industry is non prescribing injectors deciding on the dose to administer, this is illegal as that is part of the prescription. The only way to legally administer botox is if your prescriber 'sees' the patient and informs the injector of what to inject and where to inject it. All of the non prescribing nurses and beauty therapists who advise the doctor what they are doing are practicing illegally.

However, there are doctors and dentists practicing illegally also by putting 5 vials of toxin on a prescription and injecting those 5 vials into 5 different patients. Multi using a vial is illegal also. We should not tar beauty therapists and nurses with law breaking when there are many injectors in the industry not complying with some of the basic requirements of POMs.


I totally agree with Sally Ann who made the very good point that just because you have the title of Dr doesn't automatically mean that you will be gifted in Aesthetics. I am personally not a Doctor or nurse, i studied Anatomy and Physiology for 3 years and after having an interest in Aesthetics went on to study for a further 2 years in laser physics, advanced anatomy of the skin and carried out my BTEC in lasers and IPL.
I have worked in Aesthetics for nearly 8 years and own my own clinic in Surrey. Even with a lot of experience and knowledge of facial anatomy i would never attempt to administer Botox or Dermal fillers, even though i am sure i would work safer and more ethically than a lot of Doctors i have worked with in the past. As much as i agree that Beauty Therapists should not be administering Botox or Dermal fillers, i do feel that the 1 or 2 day training that Doctors receive is very poor, and although they may know what to do in the event of a medical emergency, a medical degree does not stop you making a mistake that could leave the patient looking awful for 3 months - this comes with experience.
I recently just had a Doctor leave because she didnt feel that there was enough training available to practise safely. Her training was 1 day, consisted of 8 model patients and then she was left on her own to see patients. In my opinion this is quite simply bad practice but the Doctor who did her training didnt seem to worry when we handed over a cheque for £2,000!
I dont think we need to worry so much about Beauty therapists offering these treatments, i think more focus needs to be on better training for the Doctors who feel that they should be the ones carrying out the treatments.

Kelly Harding

I believe it is unthinkable how the standard of cosmetic treatments specially injectables is going to decline, and how someone like myself who has been injecting for over 10 years would be grouped in the same category as some beauty therapist injecting Botox.Botulinum toxin being a prescription drug has to be prescribed by one of us doctors or nurse prescriber for a beauty therapist to inject.Who among us are going to do that? I was under the impression that the prescriber has to see the patient/client before Botox is injected by someone else.Free for all to inject Botulinum toxins would be a disaster waiting to happen.

Dr Ghaus Jilani

As an aesthetic therapist, I find it amusing that as a Dr you believe that the standards from medics are superior. Ive been injecting both botox and fillers for 3 years now, without a problem, without a claim. Ive over 300 clients on my books who many have had bad treatments from medics mainly Drs. I say keep up the BAD work, its doing wonders for my business!

Susan Ferndale

Susan, so you are quite happy about building your business from a patients misfortune of a poor treatment? The amount of treatments performed by non medics is vastly fewer than that of medical professionals, so to make comparisons is utterly ridiculous. You are completely missing the point here - mainly that of accountability and managing complications, which no matter how qualified as a therapist you may be, you are not medically qualified and so you are unwittingly putting your patients at risk in the event of adverse reactions and the public actually deserve better.

This is not a personal issue. If non medics really care about patient safety, go to any university faculty of health and do the graft to become a qualified medical professional. I have been a qualified nurse for over 20 years, worked in the field of medical aesthetics for half of those and gained my NIP status. Only after years of experience can one really claim to be providing the public with the respect and care they truly deserve. Anything less is damn dangerous.


Following detailed consultation with the Department of Health, Patient Organisations, Regulatory bodies and Manufacturers, the IHAS Treatments You Can Trust scheme only registers Doctors, Dentists and Registered Nurses as the medical consensus remains that restricting registration to these clinically trained regulated providers to carry out injectable cosmetic treatments is in the best interest of patients.

The IHAS scheme depends on the role of professional regulators in being able to administer disciplinary sanctions if they consider it to be warranted by the information IHAS gives them. For this reason, professions without any formal professional regulation of members pose a problem for eligibility of the scheme.

As administrators of the quality assurance scheme for providers of injectable cosmetic treatments, IHAS cannot be forced to extend eligibility criteria further than they have set them to date, with advice from their partners in the scheme. IHAS is informed by a Working Group consisting of not only its own members, but representatives from the British Association of Cosmetic Doctors, a Dental representative and the Royal College of Nursing. An independent Governance Group for Treatments You Can Trust was launched last week, chaired by Baroness Ritchie of Brompton.

Sally Taber |

I attended Professional Beauty this year and during the medical aesthetics seminar I observed a number of beauty therapists comment to Sally Taber during her presentation that they knew more about the skin than for example a nurse and therefore felt comfortable/confident to inject. When questioned, they cited that they would be able to manage an anaphylaxis or resuscitation and therefore this helped them to feel competent.

I would caution them to be aware of the following and ask them, indeed ANY injector to be able to reflect on their knowledge concerning what follows:

Recently there has been a clinical paper published on infections following a cosmetic procedure commonly carried out in the UK and in the research papers case, Switzerland. Guilieri S et al (2011) Outbreak of Mycobacterium haemophilumInfections after Permanent Makeup of the Eyebrows. Clinical Infectious Diseases. doi:10.10933/cid/ciq191.

In brief it reports on: Non-tuberculous mycobacteria are a growing cause of infection after people have undergone a cosmetic procedure. Outbreaks of mycobacterial infection have occurred after cosmetic tattooing as well as after liposuction and mesotherapy.
The above Swiss researchers report a series of 12 patients infected with mycobacterium haemophillium after cosmetic tattooing. Systemic antibiotics treatments consisting of triple drug combination was started after diagnosis and continued for three months. 10 of the women required surgical treatment, including local eyebrow excision.

This is just one paper, however as procedures become more popular and numerous, all practitioners will be seeing increasing amounts of adverse events such as:
the management of overcorrection of wrinkles with hyaluronic Acid
ischaemic events of the skin following accidental intra-arterial injection or the injectate occupying dermal space, which brings about arterial occlusion
Suspected infections of the skin

Do beauty therapists have a referral relationship with a clinician who could manage these sorts of sequelae?
Who would diagnose these patients?
Can therapists make a diagnosis, take a medical history, how would they manage patients with co-morbidities?
Who could manage these patients?
How could they be supplied with Oxygen and Adrenaline as these are both POMs?(in case of collapse)
Who would manage these patients' aftercare?
Would the NHS have to pick up the bill?

And most importantly what about the patients, who will support and care for them whilst undergoing an adverse event?

Marea Brennan Thorns MSc RN NIP

Who picks up the bill now when there's an adverse event? We do! And theres been many a bill to be picked up?
To answer your questions...We see terrible pictures of overcorrection of wrinkles all that Ive seen are via a medics injectable technique. Before anyone can make a comment on whether a therapist can undertake a medical history surely you should look at the BTEC sylabus and you may find out that answer.
This is becoming ridiculous, and all I can see is thats its all about money. If therapists do their own clients, in their own salons/clinics where would you go to make your money. Of course you dont want therapists to do these treatments.
The medics turn a blind eye to all the bad practice and disregard to POM until challenged. All I can see is that there is now a register who will regulate therapists with an inspectorate. Its more than has been out there before so why the moaning!

Maria Connolly

Hi Maria - you raise some relevent points regarding adverse events - and I agree that there are medically qualified people who are not suitably trained (and who have not displayed competence) regarding the use of these products, and I think that this needs to change. There are now diplomas and degrees available specifically for medically qualified professionals that focus on aesthetic medicine which have been spearheaded by both nurses and doctors who realise there is a deficiency in training in our market. These courses are not, however, available to non-medics and the "protectionism" does not stem from practitioners, but really from the companies who make and sell cosmetic injectables. Hence, I would still refer you back to a line in my original blog post that indicates : If the Manufacturers Suppliers and Distributors (who should understand these products, and their potential downsides more than anyone) do not think that beauty therapists (or other non medically qualified professionals) have a suitable educational background in order to use and manage the complications associated with prescription products such as botulinum toxin and dermal fillers - why are they so vociferous in ther argument? Do they truly believe that they're "providing the best and safest way to deliver these treatments" - or is it, as you posed in your comment "all about the money?" Also - the industry is changing, and more and more medically led aesthetic clinics are opening every year - and consumers are starting to recognise the distinction between a salon and a medical aesthetic clinic.

Ron Myers |

***Press Release***

The British Association of Cosmetic Doctors has spoken out against the CITA (Cosmetic Treatments and Injectables Association), a new association that has been formed this month by Chairman Molly Hanson-Steel, which has openly set out to challenge the Independent Healthcare Advisory Services (IHAS) and its Treatments You Can Trust Register which excludes practitioners who are not doctors, dentists or registered nurses from its government backed quality assurance accreditation scheme for cosmetic injectable providers.

Although the debate about who should be administering cosmetic injectables has been raging for some time, it has now entered an entirely different level with some beauty therapists trying to validate their claims to the use of a prescription medicine (botulinum toxin) and dermal fillers for cosmetic rejuvenation.

As Mike Comins, President of the BACD says:

‘The BACD has always viewed injectables as medical cosmetic treatments with recognized medical complications. Although injectable serious complications are uncommon they can occur. We therefore urge anyone thinking of having these treatments to ask about potential risks and whether the practitioner has the medical expertise and qualifications to manage these risks.

Dr Samantha Gammell, President Elect of the BACD comments:

"None of the major suppliers and manufacturers of cosmetic injectables support the use of their products by non-medically qualified practitioners so why are beauty therapists so adamant that they should be able to use them? Botulinum Toxin is a prescription only medication and fillers are medical devices, therefore as their name suggests they are fundamentally medical procedures requiring a detailed knowledge of anatomy, physiology, pharmacology and dermatology together with specialist training in each procedure.

A one day training course does not provide non-medically qualified ‘therapists’ with the depth of knowledge required for these types of treatments nor the understanding or skills to deal with the complications that can occasionally arise from them. The public needs to protect themselves by demanding to be treated in a safe medical environment by a competent, well trained cosmetic doctor or a suitable healthcare professional who makes the patients interests his or her first concern. It may be cosmetic but it is still medicine.”

The British Association of Cosmetic Doctors established in 2001 is a not-for-profit organisation, created for the advancement, education and practice of cosmetic medicine in the UK. Members are GMC registered; undergo thorough background screening, training and certification.

British Association of Cosmetic Doctors (BACD)

You are still going on about the 1 day course, but there is the large framed nurse in my area, who has failing eyes, who has been pushed into admin, she has carried out the "ONE" day course, is she better that a therapist, who has had special training, not a 1 day course, but specialist training for a long period, I don't think so, your comments Ron, along with the Doctors, are very bias, its nothing to do with safety, as I have just given you an example. The example I have given is out there as well..... in many cases.

Nancy Evans

Hi Nancy - As mentioned in my blog - I would still ask the question why not one of the manufacturers or suppliers involved in the cosmetic injectable industry feels that these products should be used by someone without a medical qualification? I agree with you that there are many poor medical injectors out there aswell - and this is a broader issue - but if any non-medically qualified person (beauty therapy trained or not) can gain access to these products, then I think that safety will be an issue. Once we say its fine for beauty therapists to use these drugs - whats to stop ANYONE injecting??
Also - if we say its fine for therapists to use prescription drugs such as Botox- then do what's to stop them using and offering other prescription items in their business models??

Ron Myers |

Can I ask what are your thoughts on Paramedics injecting.

Craig Daniel

Currently I'm not aware of any manufacturer or supplier who would directly train a paramedic - so I guess that they don't necessarily feel that their background is suitable Craig.

Ron Myers |

Thanks for your reply Ron, just to let you know I am a Paramedic that has had training, I have Insurance and I have accounts with Pharmacy's. I personally would like to be able to help my profession progress onto this field. I was just wandering what people's thoughts were on Paramedics injecting. I know there will not be many that want to get into this field and I have a lot of ribbing from colleagues about what I do, but I make people feel happy about the way look and that gives me great job satisfaction. If there was anything I could do to promote our profession within the aesthetic industry then I would gladly head it up.

Craig Daniel

Well said Craig. I would look at joining the CTIA as they may have some sympathy regarding your query. Ironically reputable suppliers are suppying, but it seems that theyre hedging their bets and supporting both causes! If youre a good injector and have the experience go for it. Again ironically its the medics teaching non-medics so they cant be that against it or believe it to be such a problem afterall?


Why dont they come out with a separate 'cosmetic aesthetic' accredited course that ALL practitioner, qualifications what not have to do? I teach the IPL & Laser course now that is for Beauty therapists & medical practitioners. So why not fillers then all will be trained & qualified accordingly...


Hi Ron- I have a beauty therapy background and have also now been working within the aesthetic industry for the past 10 years providing laser treatments chemical peels and such, all side by side with doctors from different training backgrounds from, a GP, laser eye surgeon and also dentists some of the treatments they performed I feel have left a lot to be desired the GP used to inject herself and in my opinion looked disfigured as did the majority of her patients! On what grounds does this make her anymore competent than say I would be?
All I really have to say on this matter is that I clearly have an excellent understanding of facial structure I also have a degree in human biology, so why can’t an accredited course be there for those wishing to attend and IF they can pass to the accepted standard, then surely they should be allowed to practice? Would the course not provide such standards? Just because you have a nursing qualification or Dr Status does not make you automatically able to understand how a face should look! This I have seen in my years of practice. It also does not make you able to perform good facial contouring procedures. I would like to add I haven’t any desire to inject fillers or botox however I feel I am more than capable of passing such a course if one ever came into life…!
I feel as it stands you should be on the fight to ensure all doctors nurses and dentists performing such facial aesthetics are capable of doing so and ensure they have gone through rigorous training (not two days) rather than putting your energy’s into excluding a section of the industry who are probably more capable!
I also feel Dr Dobson’s derogatory comment enrol on a beauty therapy course to become’ a real doctor’ is very unacceptable from a supposed professional. One choses a career path in life for passion of the work we do not for a status or letters before our name! I am sure many of the technicians and therapists I have met throughout the years could also have been doctors had they had the desire to do so!


Thanks for your comments Donna. I agree that training requirements are not suffice - and this is due to the lack of any effective legislation in this sector. However, I do firmly believe that if you're going to offer these products, you need to know how to help clients when you have an adverse event - and, invariably, this needs medical experience. The suppliers of these products have clearly drawn the line in terms of who they feel is suitably qualified to use cosmetic injectable treatments - and not one of them will support anyone who does not have a medical qualification because of the aforementioned reason related to side effects. The issue is not one of technical ability, but one of being qualified to deal with (on rare occasions) a medical emergency related to treatment.

Ron Myers |

I am a qualified Beauty Therapist & Massage Therapist NVQ Level 3 City & Guilds - The debate on Botox & Fillers, are now part of the beauty industry, and should now be another exam/qualification for Beauty Therapists at a certain level of experience, in our exams we are required to learn A&P which is all about blood cells/skin tissue/nervous system/muscles/bones if you then want to add Botox to your CV, I can't see why we cannot perform this task, when we are already trained in Body Piercing / Electrolocis / Micro-current Facial / Galvanic Treatment etc....Plus, why would you trust a dentist to do your Botox & Filler injections I'm sure I'd prefer someone who is highly training in Beauty Therapy!


beauty therapists are not asking to inject people purely on there beauty therapy training, they want better training courses to learn what they need to know. this could be a one or two year course, additionally or combined with anaphylactic shock training. we study the skin and muscles of the face extensively. i know nurses who have attended beauty therapy courses who did not know most of what was taught in regards to the anatomy and physiology. our profession is beauty, facial injectables is such a big part of the beauty industry that it is ridiculous there are no suitable training courses for us.


Hi Ron and Craig
I am very much aware of paramedics performing treatments and equally know how good they can be. However I feel that it is fundamentally important that any practitioner is able both to respond to emergency situations and deal with complications. Beauty therapists (not to underestimate their knowledge of anatomy) fall into neither category. Paramedics and nurses are well placed to respond to emergency situations. However only prescribers are able to deal with the fully range of potential problems that can and do occur, even in experienced hands.The above comments from beauty therapists are accurate but blissfully ignorant of the serious problems that do occur and which they will be unable to resolve. It is no argument to say that because a problem has never occured, it never will. I believe the ability to prescribe and use such drugs as hyaluronidase, steroids and antibiotics in addition to the obvious O2 and adrenaline should be prerequisite.

Andrew Rankin

Let's all be realistic, and look at this realistically, it is not rocket science and it certainly does not take the brains of an arch bishop to administer Botox.

Doctors are getting there knickers in a twist, because they see it in a completely different light than the ordinary jo that hasn't received medical training.

The years of education an individual has to go through to become a doctor is amence/torcher, I would hazard a guess and I am 100% sure I am right, if there was a 5 day course to hand that would cover all you required to know regarding administering Botox, with a written exam, there would be no harm what so ever in a beautician being able to do this.

What if this problem or that problem was to arise, how many problems has there been, regardless of always being ready for worst case, will the problem be life threatening (can this be covered on the course), and surely on a worst case scenario, A&E are always on standby.


I have never been against beauty therpaists performing botox or fillers, if they have undergone adequate training to deal with complications, and take full responsibilty legally and professionally for the practise. However the blase attitude towards a prescription medication above, may have altered my opinion.

I think it is important not to forget that "botox" is a prescription only medication...would we be quite so flippant with blood pressure tablets I wonder? If a NIP or Doctor were to make a prescribing error of botox, that resulted in morbidity or mortality! would we say never mind... its only botox?

We are not just discussing life threatening complications, what about delayed allergic reactions, infections and granulomas. Surely the professional way to manage such is to visit the practitioner that admistered the original treatment. I do not feel it is acceptable to expect the clients GP to have to deal with these possible treatment related reactions.

The consultation process we know is absoultley crucial in aesthetic medicine, and whist I accept that beauty therapists do study anatomy and physiology...but do they have a depthier enough knowledge of pathology, pharmacology and drug interactions? Its only since I became a nurse prescriber, I view this with different eyes. There is an awful lot mure to being an aesthetic nurse or Doctor than just sticking "botox" in someones face, and passing the buck to our collegues should there be a problem.

Kelly Costello

"A+E are always on standby", this is the height of imbecility.
"The brains of an Archbishop" seriously, I'm crying with laughter here.

Fab Equizi

Lol handnbags at Dawn lol blah blah blah, we could go around in circles for days, weeks, months,
Nothing like a boring blog to bring the intersting people from benieth the little rock they hide under for most of there lives lol bottom line if an individual is given adequate training in a given subject and passed all test required, there is no argument, doctors, nurses etc train for years because they cover all aspects of health etc, not just the face specific. In the words of bugs bunny, that's all folks :)


A lot of very valid comments but at the end of the day until there is legally binding and enforceable regulation nothing will change. IHAS has no power to enforce. As long as a practitioner can submit appropriate policy documentation (irrelevant as to whether they if they own it / wrote it / read it / adhere to it ) they can boast a quality kite mark!! You just need to have a look at some on the "members" websites to see they don't adhere to the standards.

Eve Montgomerie

I am currently a holistic therapist, I am looking into becoming a beauty therapist also, I understand the arguement on both sides, like anything there is good and bad everywhere, but I believe beauty & holistic therapist's, should beable to give botox treatments in their salons, but I also believe it should still be regulated, so not just anyone can do the treatments. I think there should be a specialist course, for therapists, that covers everything from injecting, anatomy of face, handling medicines etc, it should be a course that takes a few years, not just a 2 day course. I also think like any treatment, it should be closely regulated and cheacked, as even the best health care professionals, can make mistakes or abuse their position. I do think its unfair, as I have spent 5 years learning my trade, and I dont want to become a dentist, doctor or nurse, and believe alot of clients, would like to have this proceedure, done in a beauty salon, but I do also understand, why only health care professionals, are allowed to do this procedure at present. I hope in the future that there will be an opportunity for beauty and holistic therapists to also do this procedure, with the right qualifications and regulations.

Rachel Pennington

I have been qualified in Beauty and have 22 years experience in the industry including teaching and leading Beauty departments. I have taught anatomy and physiology to all levels and have taught sports massage students and nurses. The qualified nurses I taught stated that they understood the delivery of anatomy and physiology clearer than when they trained and some aspects I taught were to a deeper knowledge than they had learned. Beauty therapists have a vast knowledge of anatomy and physiology and are trained to insert needles during epilation. Personal hygiene is of great importance when administering treatments involving needles.I have had to, in the past, tell a dirty looking nurse with a filthy uniform to get the Doctor to take my blood as her appearance looked unhygienic. The Doctor then did this in his suit which was a lot cleaner but probably is not laundered daily as a therapist uniform and had been seeing patients with all manner of illnesses during the course of the day. (Food for thought fot those of you who oppose therapists) I am in a majority in the Beauty Industry in saying longstanding therapists have the knowledge, experience and skill to be trained in Botox. It is nearer to our industry skills than that of a nurse and the opposition to therapists having this training is so dentists, Doctors and nurses can monopolise the market and charge extortionate prices to top up their highly paid salaries.

Jane McNally

I am a Level 3 Beauty Therapist competently trained in Dermal Rolling, Skin peels including TCA and I also work as a carer. Along with completing anual manditory traning including Basic life support, Health & Safety- I also undergo Medication Training (provided by Boots) as I independently adminster all kinds of medications. I am now also at the end of my first year on a Foundation Degree in Health and Social Care and yes- I am interested in completing a Dermal Filler Training course with the intention of gaining appropriate insurance after.
...All that being said, I do believe individual cases should be evaluated without Industry personnel's being judgemental towards 'ALL BEAUTY THERAPISTS'

Suroya Clarke

who will insure beauty therapist lvl3 to administer botox, i have been on botox course. I have found one insurer cathedral do u no to any other plz....???????


So is there any legislation that prohibits injections by a beauty therapist, or as it was mentioned earlier " there is nothing illegal about administering Botox and because dermal fillers are medical devices (and so fall outside the Medicines Act 1968 and associated regulations) there is quite simply nothing to stop them doing treatments provided that the patient is aware that they are not doctors/dentists/nurses" ? I presume it's only up to therapists and Insurance companies and clients?


Correct Sandra. There is currently no direct regulation to prohibit Beauty Therapists from administering Botulinum Toxins and Dermal Fillers. They would need a prescriber for the toxin, to see the patient face to face and prescribe the drug with instructions or directions to administer. Then it comes down to adequate training certificates, product supply and who will sell to them based on their qualifications and whether they can get insurance and also honesty with the client in terms of not pretending to be a medic or similar, which of course would be illegal and classed as fraud, but declaring their status as a therapist and providing evidence of training if asked etc. The Health Education England team are currently looking at training standards and qualifications across the board to tighten up on requirements for the administration of cosmetic interventions such as injectables from beauty therapists through to medical professionals. I hope that answers your question.

Lorna Jackson |

Depending on which country and which state regulation differ.
Though for Australia IPL/Laser are not permitted without a licences, only in WA/QLD & VIC.
I just completed training in regards to Advanced Cosmetic Dermal Science
and Have a DIP in Psychology and other areas. I trained with three nurses, one of which I had to explain,how CPR works, before the brain start to die as I felt obligated after her trying to tell me; that we do not carry oxygen in our blood.
Now she has been a surgical nurse for 8 years, it felt so un-fare, that I have to study more than her simply because of her status, when obviously I knew a lot more than her about these specifics; With much appreciation to Advanced Cosmetic Dermal Science.

Jennifer W

My inspiration into my study was brought about from my own dissatisfaction of treatments and the feel of simply being rough-ted; As I endeavoured deeper into my study's and training with experts, frustrations to tell the world, set in; as I met more and more men and woman that were simply not satisfied, diagnosed or treated correctly.
The difference being where your actually trained to diagnose one on one skin types and conditions combined with the patients consultation, we than suggest the most appropriate treatment type individually to suit both skin conditions and the patients life schedule - we could not treat in any other way, as it would contradict what we stand for: Were as others-you can simply go in fill in the Form and pay for what you want or what you ! think.
I have since learnt the difference and find my study's both exciting and amazing. I love sharing that amazement with other's.
In fact, even in a suggested peel to a client whilst training, she sat up when finished looked in the mirror. and said, WOW
It is amazing and rewarding, for both myself and persons experiencing these natural highly professional treatments.

Jennifer W

Training for FDA Skin Methods

If I were to put a serious debate towards the board / I would argue these concepts for the cosmetic therapist (non-Dr ) If we were to introduce some of the newer technology's, similar to the electric derma needling pens-were the pen has a rotator to adjust the needles to the exact depth for each section of skin type area; there is now a dermal filler needle that acts in the same way; And lets say, we fill it not with a filler, but with plasma instead.
What would your argument than be? Not the injection, but the taking of ones own blood. Were as now, they already have machines at hand for the plasma separation.

Jennifer W