Treatments You Can Trust Launches New 7 Point Plan

Posted on the 25 January 2012 at 13:33

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.


Treatments You Can Trust Governance Group


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 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.

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Blog Comment(s) [4]

Interesting to hear that Sally Taber is still obsessing about Remote Consultations. Rather than the 40,000 Remote Consultations that I have personally carried out without a single patient complaint or claim it is the 40,000 PIP implants, the majority of which were implanted by the handful of private clinics/hospitals that have registered with IHAS that should have drawn her attention. Of the 3-4,000 independent practitioners in the UK none are currently listed as members on the IHAS website! The NMC have recently dropped the investigation of a complaint regarding the use by a nurse of the remote consultation service offer by Harley Aesthetics. In recent newspaper articles the Medical Director of the NHS, Professor Sir Bruce Keogh, has stated that Remote Consultations in General Practise and Dermatology will be routine within a year.

The various quotes and sound bites from the IHAS regarding the PIP scandal have done little to convey the image of an independent regulator with the aesthetic patient’s best interests at its heart. Audited data on complication rates must surely be the starting point for any medical regulator. Sally Taber initially did not have any data to present at all, and when the IHAS finally did forward the statistics on rupture rate from its members (reported at 1-2% rupture rate for PIP implants) it was considered so under reported by the NHS medical director, Prof. Sir Bruce Keogh, that it was totally disregarded.

The sound bite from sally taber that the aesthetics industry ‘was reasonably well regulated’ (by IHAS) must surely sound hollow in both medical and non-medical circles. There is now a growing chorus of government ministers, doctors, MPs and patients calling for effective regulation of the aesthetics Industry.

dr mark harrison

I feel strongly that regulation in the correct manner is the way forward. The lack of training standards for BOTOX treatments alone is frightening. The sooner we get a grip on this practice the better.

Q Clinics

The Independent Healthcare Advisory Services, responsible for managing, wishes to thank Ron Myers for his positive report on the Parliamentary reception held at the House of Lords on 24th January, hosted by Baroness Ritchie of Brompton, Chair of the Treatments You Can Trust Governance Group. We were delighted that Parliamentary Under-Secretary of State for Health Anne Milton was able to attend the reception and announce her continued support for

With regards to Dr Mark Harrison’s comment on remote prescribing, he quotes Professor Sir Bruce Keogh who has previously stated that Remote Consultations in General Practice and Dermatology will be routine within a year, but that is a very different agenda to those patients who make a choice to have cosmetic injectables and who should be treated differently. Remote prescribing guidance has been provided by the General Dental Council and the Nursing and Midwifery Council for cosmetic injectables.

Patients continue to be put at risk by unqualified and unregulated practitioners of cosmetic injectable treatments who are not able to clinically assess patients and lack the clinical background required to conduct these treatments safely. The IHAS has for many years campaigned for an end to remote prescribing practices and has successfully worked with professional regulators the Nursing and Midwifery Council (NMC) and the General Dental Council (GDC) to tackle this issue amongst their registrants. Most recently, on the 25th January the IHAS had an encouraging meeting with the General Medical Council (GMC) to hopefully gain their support on our longstanding agenda to end remote prescribing ensuring patient safety in the cosmetic injectable industry. It is important that Dr Mark Harrison realises that the Independent Healthcare Advisory Services (IHAS) is not a Medical Regulator – that is the role of the General Medical Council (GMC).

Sally Taber |

There is no coherent logical reason why patients having cosmetic injectable treatments are any different to patients in general practice or dermatology. Sally Taber’s objection to Remote Consultations in Aesthetics, as stated in a BBC radio interview last year, was the inadequacy of taking a Past Medical History. The NHS obviously does not agree as it is adopting the Practice.
The Nurses that use Harley Aesthetics Remote Consultation Service are all well trained, well qualified, have an enviable safety record and are regulated by the NMC.
I am sure the GMC welcomed advice from the non-prescribing nurse sally taber on how a doctor should conduct a consultation. Despite several years of claiming a role in regulating the Aesthetics Industry it appears the IHAS has been relegated to providing subsidised marketing for a handful of clinics and private hospitals. Given that it was these members who were responsible for the majority of the PIP implants the irony of the 'treatments you can trust' brand is plan for all to see.

dr mark harrison