The JCCP has recently published it’s wide-ranging ten-point plan to “…create a safer environment for members of the public undergoing non-surgical treatments with mandated qualifications, premises criteria, insurance and many other steps relating to the sector and industry.”

It’s meant to be the future of aesthetics. Cosmetic CEO Maxine McCarthy has broadly welcomed the plan and has offered to help and advise the JCCP on a way forward in some very specific areas. Here’s her view.

“I would broadly like to welcome JCCP 10-Point Plan for Safer Regulation in the Aesthetic Sector which was published earlier this month.

Within a few hours of me sharing my thoughts on the new JCCP plan we were told of an advert for a training course for non-medics at “level 7 equivalent” in just six days.

How can someone really train in just a few days from start to finish?

And what also infuriates me is all the courses that claim they offer level 5 or level 7 qualifications in aesthetics. No-one recognises these. This plan make it clear that there is a major need for a standardisation of qualifications and to clear out all the nonsense and courses that take money without delivering adequate training. Let’s get it done!

So, I can see why the JCCP and others get really frustrated with our industry because sometime we are doing ourselves no favours.

How can you get a postgraduate qualification in just six days?

So, after taking time to read and understand the JCCPS’s aims and objectives I have offered the help of both Cosmetic Couture and The Association of Cosmetic Practitioners Britain to move the plan forward.

While there are there are several issues, objectives and proposals with which we would disagree, in broad terms we welcome much of the plan and would happily and publicly give our support.

The main disagreement is with the aim of the plan to make dermal fillers a ‘Prescription only Device’ – NO. We can’t support that.

But for the first time an easy-to-understand plan has been created – it’s taken long enough – which gives both medics and non-medics a clear understanding of what the JCCP hopes to achieve.

So, we have written to the JCCP to offer our thoughts and comments on the plan and have offered help with specific ideas where we think we are already ahead of the JCCP.

The first major aim of the plan is to make aesthetic treatments legal only for over 18s, (except in the case where explicit medical evidence exists to confirm the necessity of such interventions) and we agree and support that 100%.

The JCCP plan talks a lot about education and training and we have stated that we believe access to all levels of qualification in aesthetics should be open – via a recognised progression framework, to all. This should be via the creation of levels 4 to 7 in aesthetic theory & practice OR via alternative and recognised, relevant academic regulated qualifications. A progression from level 3 to 7 must be open to all and is CRITICAL for the industry to cohesively come together to achieve change which protects the public and safeguards the careers of ALL professionals in the industry.

We believe the JCCP has a crucial role to play here following on from the JCCP’s decision in July 2018 to restrict registration for both botulinum toxin and dermal filler injections to Healthcare Professionals only. This will be reviewed in August 2022 and we urge the JCCP to rethink.

On advertising we agree with the JCCP that regulators must take firmer action against those flouting advertising rules and regulations while creating much more impactful campaigns to inform the public about the benefits and risks of treatments.

We have again offered to help as we believe the JCCP is a little detached from the real people who don’t watch Government adverts or take notice of Government websites and campaigns. We are quite good at marketing!

We also agree with the need to clearly define in law what is medical and what is a cosmetic treatment and we also agree with proposals to enforce the requirements around prescribing.

These exist in law now. It is interesting to note that the only area where regulations do exist in our mostly unregulated industry relate to medical professionals and are largely unenforced.

With the exception of two points, we agree with all the proposals in the plan around social media and advertising.

We don’t believe promotional discounts should not be communicated nor do we believe competitions and prizes should not permitted if promoted responsibly.

This is a business after all!

We believe before any more plans are put forward a wide-ranging national research programme should be undertaken to assess all the factors highlighted by the JCCP:

They themselves say: ‘The existence of an acknowledged evidence-based gap with regard to the lack of data, research relating to the non-surgical sector should be addressed as a priority – such as: the size of sector, the number and type of practitioners who operate in the UK (including details of their professional backgrounds and training), the procedures carried out, the products, and the value of the industry to the UK economy. In addition, data is required on the number, type and extent of complications that occur as a result of aesthetic treatments, how these adverse events are reported and the cost to the NHS of correcting such complications.’

We agree and we call for an independent root and branch Government funded survey of the UK aesthetics industry.

We also agree and support the proposals regarding insurance.

We agree that in order to gain insurance, there should be a requirement for all practitioners to demonstrate relevant knowledge and competence in the provision of cosmetic treatments; there is no current requirement for this, with some insurers providing cover to cosmetic practitioners after the completion of a short course (1-2 days) with no assurance of competence, safety or proficiency.

We agree and have implemented with ACPB a requirement that all members of the aesthetic community who wish to become members are required to provide proof of valid insurance.

In addition, ACPB offers complimentary CPD as part of it’s annual membership fee – another area where we seem to be in tandem with the thinking of the JCCP to improve and stress the importance of CPD.

We have offered to share detail on The ACPB Code of Practice and requirements for membership as an example of self policing and best practice.

Another area where we have offered to share how we are already acting to help increase public safety and form a proper plan to take action is with reference to licensing of premises.

Here the JCCP wishes to use existing networks to develop and implement legislation that is fit, responsive and adequate to protect members of the public.

These organisations are listed variously as the Chartered Institute of Environmental Health (CIEH), the Institute of Licensing (IoL), and the JCCP.

We would suggest adding The ACPB to this list as it has created an independently audited Inspectorate.

This is self-funding and existing self-regulating inspectorate of premises – a start at least and a step in the right direction. It does not rely on Local Authority input or resource and has been created to be an independent 3rd party auditing services against a set of criteria which are in line with the latest national cosmetic standards.

The ACPB is determined to show that non-medics working in aesthetics are working to a high set of standards and are willing to be scrutinised and the results made public.

It has produced an audit checklist to monitor practitioner compliance against the latest cosmetic standards (CPSA, CQC and relevant data protection elements of ISO9001) – referring exclusively to the availability of resources, equipment and procedures appropriate for the delivery of cosmetic injectable treatments.

We have said we are happy to discuss how this could be integrated into a national strategy to begin the process of self-regulation in advance of any secondary legislation regarding licencing of premises.

And finally, and along with the JCCP, we welcome all activity which increases public awareness of safety and best practice – and would once again highlight using experts in the industry to get the messages across to those who need to understand that the most.