Scottish Cosmetic Interventions Expert Group minutes: May 2024

Attendees and apologies

Andy Malyon (AM) (Scottish Government (SG) and NHS GG&C) – Chair

Lorraine Alcock (LA) (SG)

Lesley Blair MBE (LB) (BABTAC and CIBTAC)

Sara Davies (SD) (SG)

John Elder (JE) (BCAM)

Martin Gibb (MG) (Glasgow City Council)

Tom Gorman (TG) (Glasgow City Council)

Elaine Hutton (EH)

Anne Macleod (AMac) (South Lanarkshire Council)

Winnie McLure (Healthcare Improvement Scotland)

Jackie Partridge (JP) (Dermal Clinic & BACN)

Julie Wales (JW) (Glasgow Clyde College)

Annalena Winslow (SG)

Rachel Coutts (SG)

Joanne Gosney (SG)

Silvia Soriano-Rivera (SG)

SG official

Apologies:

Kevin Freeman-Ferguson (Healthcare Improvement Scotland)

Jenny Hunt (JH) (SG)

Alun Parry (AP) (SG)

Joanna Swanson (JS) (SG)

Items and actions

Welcome and introductions

AM welcomed everyone to the meeting and reminded those attendees, who have yet to do so, to email their completed declaration of interests forms to SCIEG secretariat. 

Action Point
Any attendee who has not yet done so to return their completed declaration of interest form to SCIEG secretariat before the next meeting.

Agreement of minutes

The minutes from the meeting on 25 March were agreed with no amendments.

AM reminded the group that the minutes of meetings of the reconvened SCIEG (from November 2023 onwards) will be published on the Scottish Government website. Anyone not wishing to have their names published with the minutes should let SCIEG secretariat know as soon as possible.

Action Point
Anyone not wishing to have their names published with the minutes should let SCIEG secretariat know as soon as possible.

Hot Topics

AM provided members the opportunity to update the group on their areas.

Glasgow City Council

Following on from the update from Edinburgh City Council at the 25 March meeting regarding an unregulated non-surgical cosmetics provider from England travelling throughout the UK to provide certain non-surgical cosmetic procedures, TG advised that following a weekend visit to a Glasgow hotel to perform non-surgical cosmetic procedures, Glasgow City Council issued three Health & Safety prohibition notices, one each on two separate companies, who advertised, arranged and took payment for the procedures to be carried out and the other on the person who carried out the procedures. 

TG advised that evidence, including medical opinion, is required to back up any prohibition notice and that prohibition notices can only be issued on Local Authority by Local Authority basis for services operating within each Local Authority boundary. John Elder (BCAM) offered his medical expertise. TG highlighted that due to the number of aesthetic clinics within the Glasgow City Council area, together with the diverse nature of procedures being carried out, some bordering on surgical procedures, the enforcement of this sector required a significant amount of resources.   

TG informed the Group that he has been invited, by Epping Forest District Council EHO, to a Teams meeting which will include representatives from the Chartered Institute of Environmental Health (CIEH), Joint Council for Cosmetic Practitioners (JCCP), British Association of Aesthetic Plastic Surgeons (BAAPS), and EHOs from Local Authorities in England to discuss the possibility of the JCCP and expert clinical stakeholders drafting a letter to provide “back up” to EHOs who are considering enforcement action with regards to BBL and other high risk procedures.

TG asked if there could be a national campaign to advise the public to undertake their own checks prior to undertaking any non-surgical cosmetic procedures. AW asked if collective action / communication from Directors of Public Health and Boards would help and whether EHOs had been in contact with theirs.

Action Point
John Elder to provide medical expertise to EHOs 

Action Point
Scottish Government and TG to discuss possible messaging through Directors of Public Health.

BCAM

JE advised that he had reviewed JCCP’s response to the England consultation and he was happy to share this with the group

BACN

JP asked about the HIS review on ventilation which HIS said they would pick up in their update

Colleges

JW accepted an invitation from the Chair to represent the Colleges and she introduced herself to the group. JW said that she works for Glasgow Clyde College and leads on healthcare and beauty therapy.  

BABTAC

LB said that she is happy to share BABTAC’s response to the UK non surgical cosmetics consultation.

South Lanarkshire Council

AMac advised that the Skin Piercing Short Life Working Group continues to work on the guidance and leaflet for EHOs.

South Lanarkshire Council has followed up on concerns regarding some unregulated services providing non-surgical cosmetic procedures.

Scottish Government Update

LA advised that the Scottish Government has been engaging with various stakeholders including the British Beauty Council, Save Face, dental policy colleagues and a dermatologist from Glasgow who would like to develop an education package for schools regarding body image and the risks associated with certain procedures e.g. sunbeds, dermal fillers. 

Further engagement will take place with regulation and medicines policy colleagues regarding reserved legislation relating to healthcare professionals and medicines.

LA advised that Save Face are developing an education package with Leeds City Council and have advised that they would be happy to share this package with the Scottish Government and the dermatologist. LA asked if members of SCIEG would be able to provide advice to the dermatologist regarding non-surgical cosmetic procedures.

Action Point
SCIEG members to advise LA/ SCIEG secretariat if they are able to provide advice to Glasgow dermatologist for school education package. 

LA advised that following on from the 2020 Scottish Government consultation which was overwhelmingly in favour of further regulation of the sector, further consultation will be required to help determine the specifics of any potential future regulation and what legislation may be required.

JE asked if formal legal advice could be provided on what existing laws are currently being broken by (unregulated) non-surgical cosmetic providers. SG reminded the group that each organisation needs to seek their own legal advice and there is guidance from the Medicines and Healthcare products Regulatory Agency (MHRA) on the GB Regulations.

JE stated that BCAM and BACN had been approached by A&E departments to deliver training on managing dermal filler complications. AM suggested that it may be worthwhile to contact NES directly and that he could make contact. The Scottish Government can also contact its NES Sponsorship team.

Action Point
AM to make contact with NES for JE.

Action Point
Scottish Government to contact NES Sponsorship Team regarding training on managing dermal filler complications in support of AM if required.

Healthcare Improvement Scotland (HIS) regulated clinics and future red/green lists

HIS Clinics

WM updated the group on developments at HIS including that independent healthcare services provided by pharmacists and pharmacy technicians and independent medical agencies, including independent online services provided by medical practitioner, registered nurse, registered midwife, dentist, dental professional, pharmacist and pharmacy technician based in Scotland, will come into scope of HIS regulation from 19 June.  These services will have a year to register with HIS.

The HIS review of ventilation in independent clinics is ongoing and the review should be finalised and any outcomes announced by the end of the year.  In the interim, WM advised that any new clinics will require a risk assessment.

JE said that HIS requirements of independent clinics needs proportionality and expressed the view that it should be the same as for the NHS.

JP told the meeting that a nurse was refused registration of her independent clinic by HIS due to inexperience.  She will investigate this and discuss with WM.  

Future red/green lists

The group discussed the list of red and green non-surgical cosmetic procedures for possible regulation.  LA stated that the Scottish Government would require further details on these procedures to take this work forward.  The group agreed to provide information including associated risks, complication management, training required, and why a procedure should be on the red or green list.  

Action Point
LA/SCIEG secretariat to email the updated list of red/green procedures to members to provide further details.

Training Framework

The main discussion on the framework was the length of time post qualification that should be required. Newly qualified doctors do not acquire full registration until they have completed one year post graduation. Nurses, in common with other AHPs, acquire full registration on completion of their approved educational programme – although would be likely to require additional time post qualification to achieve prescriber status. In order to achieve an equitable pathway a requirement for two years’ experience post-graduation was discussed. It was agreed all would consider options for the next meeting. Members were also asked to annotate the red/green list with minimum level of qualification for procedures.

AOB

JP noted that the Scottish Medical Aesthetics Safety Group have a meeting with MSPs regarding the regulation of non surgical cosmetics procedures at the Parliament on the 13th June. 

Close

LA thanked the group for attending and will be in touch regarding the next meeting, this may potentially be in August rather than July due to holiday period. 

List of Action Points

1.    Any attendee who has not yet done so to return their completed declaration of interest form to SCIEG secretariat before the next meeting.
2.    Anyone not wishing to have their names published with the minutes should let SCIEG secretariat know as soon as possible.
3.    John Elder to provide medical expertise to EHOs 
4.    Scottish Government and TG to discuss possible messaging through Directors of Public Health.
5.    SCIEG members to advise LA/SCIEG secretariat if they are able to provide advice to Glasgow dermatologist for school education package.
6.    AM to make contact with NES for JE. 
7.    Scottish Government to contact NES Sponsorship Team regarding training on managing dermal filler complications in support of AM if required.
8.    LA/SCIEG secretariat to email the updated list of red/green procedures to members to provide further details.