IQ Calls for A More Informed Debate on Injectables

In the lead up to the announcement of an official Government response to the Keogh review, the debate over whether regulation of the injectable cosmetic industry is needed and the manner in which it should be introduced is intensifying. 

The Review of the Regulation of Cosmetic Interventions, also known as the Keogh review, was carried out by Professor Sir Bruce Keogh earlier this year at the request of the Prime Minister and was set up in the wake of the PIP breast implant scandal. Published in April, it made a number of key proposals, including that all dermal fillers should be available only through prescription and that all cosmetic practitioners should be properly qualified to deliver the procedures they offer.

Upon its publication the review was widely welcomed by industry experts and independent observers alike as being a thorough study that reached a number of sensible conclusions. With regards to training for non-surgical cosmetic procedures, for instance, the report stated that:

[3.11] ‘Historically the argument over “who” has been adequately qualified [to deliver non-surgical cosmetic procedures] has distracted from the question “what should adequate training and accreditation involve?”’

It went on to suggest that it should be possible, once training requirements are understood, to identify ‘for each professional group…including those with no prior experience’, which skills are required in order to perform these procedures ‘safely and to a high standard.’

Perhaps unsurprisingly, however, after a brief hiatus, this summer has seen a resumption of the jockeying for position in the court of public opinion, with the interests of the supplier often being placed before those of the customers. Questions have again been asked by those with vested interests, in the medical sector in particular, about the legitimacy and ability of the cosmetics industry to provide treatments. The fact remains, however, that there is little data to identify the number of treatments provided, whether they are provided by the cosmetic or medical industry, or indeed the number of treatments requiring the intervention of the medical fraternity. Even less is known about where responsibility for those customers experiencing problems lies. In this environment, sensationalist claims go unchallenged.

The journalistic coverage to date has sadly not shed any real light on the issue.  Far too often, the unsubstantiated or exaggerated claims and headline grabbing PR of the medical industry, in particular, are taken at face value. Despite the valiant efforts of one small trade association, the cosmetics industry has failed to deliver its message with vigour or clarity. In the absence of journalistic rigour, or indeed a coherent voice from the cosmetics industry, it might be argued that the cosmetics sector runs the real risk of becoming a convenient fall guy for the commercial aspirations of some in the medical industry.

With the market for cosmetic interventions expected to grow to £3.6 Billion by 2015, perhaps it is not surprising that key interest groups are positioning in a way that ensures that their members claim the largest possible slice of the pie. In this desperate and self-serving attempt to gain traction on the debate we risk losing sight of the interests of the customer (not patient as it is an elective, commercial transaction). Surely, customers should have a right to know that the person administering the treatment has been trained and qualified to a common and approved national standard, that the organisation and premises are inspected to agreed industry standards on a regular basis, and that the materials used are safe?

Whilst there is a small risk inherent with any injectable treatment, these risks exist irrespective of the skill of the practitioner. This is precisely why Keogh is right to have called for adequate training; so that practitioners are aware of these risks and know how to deal with them should they arise. The review was also right to recognise that these skills do not have to be the sole preserve of doctors or nurses, who are in short enough supply as it is, but instead should be open to delivery by those that meet agreed standards.

Perhaps it is time now to cut the noise, and start to define those standards and to develop the mechanisms to allow real data to be collated and analysed in order that stakeholders in the sector can be confident that decisions are anchored in fact and not self-interest. It should not be a case of the interests of the cosmetic sector versus those of the medical industry, but a case of co-operation to ensure that the needs of the customer are best served.

Notes to Editors

Industry Qualifications (IQ) is a regulated awarding organisation that is working with the Associations of Aesthetics and Injectable Cosmetics to develop qualification standards to submit to Health Education England for its review. IQ Verify, a wholly owned subsidiary of IQ has recently acquired cdBAFI, a specialist inspection body for the cosmetics industry that has been inspecting organisations offering injectable cosmetic treatments since 2011. Full details of IQ are available on the IQ website

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