The Department of Health backed Treatments You Can Trust register celebrated the 2nd anniversary of their self regulation register related to clinics and practitioners offering injectable cosmetic treatments such as Botox® and Dermal Fillers. Over 40 industry participants, regulators and suppliers were invited by Baroness Ritchie of Brompton, Chair of the Treatments You Can Trust Governance Group, to attend a reception last Tuesday 24th January 2012 in one of the House of Lords private committee rooms.
A glass of House of Lords wine was enjoyed alongside comments from a panel including: Dr Andrew Vallance-Owen, Group Medical Director, BUPA; Christine Braithwaite, Director of Policy and External Relations, Council for Healthcare Regulatory; Sally Taber, Director of Standards & Training Principles; Anne Milton, MP for Guildford and Parliamentary Under- Secretary of State for Health and Baroness Ritchie.
Sally Taber announced the 7 challenges that the group have targeted in terms of their focus for future development of the scheme to help improve standards in this sector of the market.
1. Reduction in the number of dermal fillers available in the UK market
With over 160 different dermal filler brands potentially available for clinics to purchase in the UK versus only half a dozen in the USA – due to stricter FDA approval requirements for dermal fillers, it is worrying (especially in the light of the recent debacle regarding PIP breast implants) that stricter guidelines are not in place to evaluate safety data relating to dermal filler products.
2. Restricting foreign supply of dermal fillers to UK suppliers
In addition, non CE marked dermal fillers or even counterfeit versions of established leading brand names are also promoted via internet shops from the Far East providing additional concerns regarding patient safety.
3. Clamp down on issues surrounding nurse prescribing
The NMC and GDC have both given written statements regarding the issue of the use of prescription cosmetic injectables by nurses who are not qualified to prescribe and operate their business using remote prescribing services. Treatments You Can Trust are seeking the same support from the GMC to provide a consistent message to Doctors providing prescriptions for non-prescribing nurses and therapists.
4. Local Authority Support
This challenge relates to identifying suitable premises where injectable cosmetic treatments should be performed – the aim is that they should be restricted to medically led clinics rather than beauty salons.
5. Spot inspections for registered providers
The current scheme has a random inspection process for providers currently registered. 3% of members have been inspected so far, and the plan is to expand this as the register grows.
6. To track the use of dermal fillers amongst appropriately qualified providers
Given the current dynamics of how the dermal filler market works from a distribution perspective – which includes a number of third party suppliers such as Wigmore, Med-FX , Church Pharmacy and the HealthXchange, it may be difficult for manufacturers to control who actually buys and uses their products. Sally Taber did note, however, that Merz, Lifestyle Aesthetics and Allergan all have on the side of the boxes of their respective dermal filler brands that they should only be supplied to Doctors and Nurses. The challenge is how this distribution can be monitored to restrict the use of their products by beauty therapists.
7. To launch a new consumer awareness campaign
Part of the strategy of the Treatments You Can Trust Register is to educate journalists and the media of the benefits of the scheme and why consumers should search for providers listed on this voluntary register to ensure better standards of treatment. In light of the issues raised by PIP breast implants, it is likely that the media will be more responsive to this message over the coming year.
Ann Milton, MP, gave her public support to the scheme, but voiced her concern about the desire for some sections of the industry’s call for mandatory versus voluntary regulation of this market sector. She indicated that mandatory regulation is not a panacea, and is keener to promote and make people aware of good quality self-regulation schemes such as the Treatments You Can Trust register. Forcing people to provide a level of care that they may not want to provide willingly via mandatory regulation does not necessarily raise standards effectively versus a voluntary register where providers are likely to be committed to providing a high standard of care as a business philosophy.
Christine Braithwaite also announced the impending launch of a new all encompassing Professional Standards Authority that will set standards for organisations that hold voluntary registers for practitioners who are involved in providing health and social care for people in a variety of different ways but who do not, by law, have to be on a statutory register.
The government has asked them to set up a system to strengthen public protection by encouraging organisations that hold voluntary registers to be effective. The Professional Standards Authority will set standards that the organisations holding the voluntary register should meet and will accredit organisations who apply to them (such as the Treatments You Can Trust Register) that meet their standards. This authority will accredit (or approve) them so that health and social care practitioners wanting to register, or employers, commissioners, patients and the public wanting to choose someone to work for them or provide them with a service can see easily which registers have met the standards.
The aim is that this site will be promoted to help consumers steer through the minefield of organisations, registers and professional bodies related to different market sectors so that they understand the ones that they can place their trust in when searching for a provider.
With BAAPS’ new 6 point plan and the Treatments You Can Trust 7 challenges, linked to work being performed at a European level regarding CEN European Standards (for consultation visit http://drafts.bsigroup.com/ and search for prEN 16372) , plus heightened media interest related to the PIP breast implant scandal, it is likely that “Standards” are going to be higher on a consumers agenda over the coming year.
This is particularly relevant in a period where pressure on disposable income, easier ways to compare prices on the internet, Groupon and other deal providers are all putting pressure on prices in the market as a whole.
Investment in training, premises, robust procedures, adequate insurance, ensuring that marketing activities are creative (i.e. not just 50% off) but appropriate, and fully comply with CAP and MHRA guidelines takes time and money.
It is difficult to get a message across regarding quality and standards (and the price you need to pay for these) in a market that allows a mobile beauty therapist to pay a few hundred pounds for an injectable course and advertise a Groupon deal for cut price injectables to gather, sometimes, hundreds of unwary consumers to “learn” their new trade on.
Although there are many people who criticise the Treatments You can Trust Register, without it and their activities to lobby regulators and the government, there appears to be very little else out there that is practically and concertedly trying to get to grips with driving up standards in this important sector of the non-surgical cosmetic market.