Europe Wants to Limit Cosmetic Injectables to Surgeons!

Dr Philip Dobson
By Dr Philip Dobson

Dr Dobson is Medical Director of LCS Healthcare and holds board certification under RPA 2000 as a Laser Radiation Protection Adviser.

The European Standard for Aesthetic Surgery Services (CEN TC403) is now in its second draft and due to be considered further by the committee following receipt of comments made by stake holding parties throughout the EU.

There is considerable confusion and consternation about this document and the possible consequences of it eventual implementation as a standard for the medical and surgical cosmetic sector in the UK.

The EU encourages and supports the development of standards by consensus and agreement between member states using national standards agencies. The adoption of the standards is voluntary by all parties. The confusion seems to arise with this document as to its eventual status in law. This is not a EU Treaty Article, nor a Regulation or Directive ; further this is not even a harmonised standard (which are produced in response to a Commission request to evidence compliance with a Directive).  The eventual outcome will be a standard which carries no force of law whatsoever.

There are some areas of significant conflict between accepted medical practice and UK law when compared to the proposals within the draft standard. Areas of particular concern are detailed below:

  • Many treatments using local anaesthetic are classified under category 2 procedures which should only be undertaken by doctors on the GMC specialist register – this would include ablative lasers and minor surgical procedures.
  • The document refers to categories of EU Medical Specialities – there is no such category for cosmetic doctors so no opportunity to develop skills in any other areas.
  • Nurses would be unable to provide any cosmetic treatments except under direct supervision of a doctor.
  • States that practitioners should charge for all – including initial consultations
  • Many of the procedures listed as category 2 (minor surgical) are not regulated in the UK and can legally be performed by non medically qualified staff. This would in effect mean that medical practitioners would not be able to provide these treatments even though they would be available in the local beauty clinic.
  • The provision of virtually all cosmetic procedures other than botulinum toxin, resorbable dermal fillers and Intense pulsed light treatments would be restricted to plastic surgeons and dermatologists to the exclusion of virtually all other medical.

So, should the cosmetic community be concerned if they do not like the content? Even with the above said it is wise to take these documents seriously. While this standard will not force any significant changes or introduce any restrictions in the short or medium term, it is just possible that in years to come it will be adopted and incorporated by the Department of Health into proposals for new legislation when this area of law is to be reviewed.

The standard continues on its journey through drafting with proposed amendments from interested stakeholders.


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