Industry expert Pete Richardson takes a look at some outputs from the recent JCCP Stakeholder Meeting as regulation gets closer and closer….
The meeting was a great place to hear what others believe is coming down the line when Government consultation starts in July on how the new law should look.
The JCCP is very clear in its own views and those can be seen across their website. Here are some of the key points discussed, many of which were highlighted by barrister Sarah Glover, an expert on licencing laws.
1. The barrister gave excellent thoughts on what the new legislation will look like – and this is PRIMARY LEGISLATION – so needs to be extremely detailed!! Breaking primary legislation means you are breaking the law and could be committing a criminal offence.
2. Walking the line between making the laws too draconian or too lenient is going to be: “no walk in the park”… so a very complex process. Hence a huge consultation process from July which everyone should make an effort to take part in.
3. Another challenge is going to be future proofing: ie taking into account of developments in the industry over the coming years. Eg some new AI-generated acupuncture!
4. Section 180 of the legislation sets the goal posts for the legislation but will cover procedures for cosmetic purposes that are non-surgical and non-dental BUT it is not yet defined what “cosmetic purposes” means!
5. BUT we know the legislation will cover the five areas where we will need new regulations, qualifications and licenses:
- The application of a substance that is capable of penetrating into or through the epidermis
- The injection of a substance
- The placing of threads under the skin
- The insertion of needles into the skin
- The application of light, electricity, cold or heat
6. The consultation process will need to cover lots of definitions eg mobile working and timeframes for monitoring of licences and qualification updates and upgrades or refreshers.
7. Civil servants and those drafting these laws will know next to nothing about the industry – they will informed by the industry through the consultation process – and that’s your responsibility!!
8. Govt will pay huge attention to industry stakeholder eg JCCP, GMC etc BUT the numbers of representations will be very important eg if 10,000 non-medics make excellent points they will be listened to.
9. The new premises licence is likely to be similar to CQC requirements AND if you have a CQC licence that may well exempt you from needing the new licence.
10. You will probably need things like a fire safety licence, and prove you are fit and proper person – so probably need to undergo police checks.
11. What standard will you need to achieve? REMEMBER doctors train to level 6 in the UK and the JCCP and other medical bodies are pushing for all this legislation to require level 7 qualifications across the board – so even micro-needling.
12. The JCCP is also pushing for threads to be considered a surgical procedure and not cosmetic and therefore only those with surgical qualifications would be able to carry out thread procedures.
13. It was agreed everyone should make their voice heard and make their points clear and rationally argued. The JCCP will be doing exactly that in association with all the professional groups with which they are aligned.
The Association of Cosmetic Practitioners Britain (ACPB) is working with it’s members to get their voice across as one of the professional groups referred to above.
Have a voice on this subject! Join the ACPB and be part of the group making their voices heard.
Join now at www.acpb.co.uk/registration