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Navigating the Government's Aesthetics Licensing Scheme: Insights from Dr. Tristan Mehta and Prof. David Sines

In the realm of non-surgical cosmetic procedures, the recent buzz around the government's new aesthetics licensing scheme proposals for England has piqued curiosity and raised numerous questions among practitioners and enthusiasts alike. To shed light on this significant development, Dr. Tristan Mehta engaged in a profound 45-minute live discussion with the esteemed Professor David Sines, CBE, on Comma.

Professor Sines, renowned for his unwavering advocacy for client safety within the non-surgical cosmetic domain, brings to the table a wealth of experience as the Chair of the Joint Council of Cosmetic Practitioners (JCCP). Their insightful conversation delved deep into the implications and intricacies of the proposed licensing scheme, offering a comprehensive understanding for all stakeholders involved.

For those who missed the enlightening discussion, worry not. Here's a comprehensive rundown of their discussion.

Professor Sines shares the government's approach by highlighting the release of the initial consultation paper by the Department of Health & Social Care on 2nd September 2023. This paper marked the beginning of a series of consultations on the aesthetics licensing scheme, signalling a pivotal step towards establishing a comprehensive regulatory framework in our industry.

Emphasising the collaborative nature of this process, Professor Sines underscores the proactive engagement with key stakeholders, including the former Secretary of State, Maria Caulfield. The dedication of a committed, cross-party government to this initiative is deemed essential in shaping the future of aesthetics regulation in England.

The Joint Council of Cosmetic Practitioners (JCCP) played a crucial role by producing three papers in March of the same year, aimed at informing the regulatory team at the DHSC about the procedures that should fall under the purview of the licensing scheme. This groundwork laid the foundation for the first consultation, proposing a risk-focused, stratified system for the procedures identified for regulation.

Looking ahead, Professor Sines hints at the next phase of consultations, with plans for a dual licensing system encompassing licenses for both the premises and the practitioners. The practitioner license, essential for those offering regulated procedures, will necessitate demonstration of competency and adherence to forthcoming standards and competencies. Anticipating a follow-up consultation in 2024, the progression towards a more structured and accountable aesthetics industry in England is clearly outlined.

In the ongoing discussions surrounding the aesthetics licensing scheme, the primary emphasis is currently directed towards categorising treatments and procedures based on the associated risk levels, rather than outlining specific qualifications required for practitioners to obtain their licenses. This risk assessment is being structured through a RAG-rating system, denoted by red, amber, and green classifications, reflecting varying levels of potential risk to patient safety.

Professor Sines underscores the importance of reviewing the consultation paper to gain a comprehensive understanding of the proposed framework. While the anticipation regarding practitioner qualifications builds and is an essential element in the licencing proposal, the immediate priority lies in establishing a structured risk-based approach to categorising procedures. By familiarising oneself with the nuances of the proposed RAG-rating system and its implications, stakeholders can better navigate the evolving regulatory landscape and contribute meaningfully to the ongoing consultations shaping the aesthetics industry in England.

Within the proposed aesthetics licensing framework, procedures are segmented into distinct categories based on the level of risk they pose to client safety. Professor Sines elaborates on the classification system, highlighting the "green" category as encompassing treatments that are deemed to carry minimal or minor risks to the public.

These "green" procedures, identified as low-risk interventions, are expected to be conducted by licensed practitioners without the necessity of direct supervision. The government's delineation of procedures into green, amber, and red categories underscores their commitment to ensuring a systematic and risk-focused approach to regulating the aesthetics industry in England.

By acknowledging the delineation of procedures and the corresponding levels of risk associated with each category, practitioners and stakeholders can gain valuable insights into the evolving regulatory landscape and prepare themselves for the forthcoming changes in the field of non-surgical cosmetic procedures. Familiarising oneself with the proposed framework, including the specifics of the green procedures, is essential for staying abreast of the developments shaping the aesthetics industry.

Transitioning from the low-risk "green" procedures, the focus shifts towards the more intricate realm of "amber" procedures within the proposed aesthetics licensing scheme. Professor Sines draws attention to the challenges associated with this category, emphasis

ing that amber procedures entail a moderate level of potential harm if not executed proficiently.

Amber procedures involve a comprehensive list of treatments, including but not limited to botulinum toxin, dermal fillers, laser treatments, and select chemical peels. These procedures demand a higher level of skill and expertise, necessitating that they be exclusively performed by licensed individuals under the supervision of a regulated or registered healthcare professional.

The concept of supervision and oversight emerges as a pivotal aspect warranting detailed clarification within the regulatory framework. As Professor Sines highlights, the definition and implementation of effective supervision protocols require collective input and careful deliberation among stakeholders. Addressing queries regarding the specifics of supervision is crucial in ensuring clarity and coherence in the execution of amber procedures, reflecting the commitment to upholding client safety and quality standards within the aesthetics industry. By engaging in collaborative discussions to refine the parameters of supervision, practitioners can contribute to the establishment of a robust and accountable regulatory framework for amber procedures within the evolving aesthetics landscape.

Delving deeper into the proposed aesthetics licensing scheme, Professor Sines delves into the critical domain of "red" procedures, which are associated with high levels of risk. These procedures, deemed as high-risk interventions, have raised significant concerns due to their potential implications for client safety, particularly in the current context where they are widely available on the high street.

The roster of "red" procedures encompasses a spectrum of interventions that include liposuction, breast and buttock augmentation, hair restoration surgery, as well as cogs and threads, among others. The gravity of these procedures necessitates a stringent regulatory framework to ensure that they are administered with the utmost care and expertise.

In light of the heightened risk associated with red procedures, Professor Sines advocates for their regulation by the Care Quality Commission (CQC) in the future. Furthermore, he emphasises that these procedures should be exclusively performed by registered, regulated healthcare professionals, underscoring the imperative of strict oversight and adherence to stringent standards to mitigate potential risks and safeguard client well-being.

By recognising the distinct categorisation of red procedures and the imperative for specialised regulation and practitioner expertise in this domain, stakeholders can gain a deeper understanding of the complexities involved in regulating high-risk interventions within the aesthetics industry. Engaging in informed discussions and collaborating towards defining robust regulatory measures for red procedures is paramount in fostering a safe and accountable environment for aesthetic treatments in England.


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