Concerns Voiced About APPG

By Shannon Kilgariff / 03 Aug 2020

Aesthetics explores the concerns raised by the medical aesthetic community about the All-Party Parliamentary Group on Beauty, Aesthetics and Wellbeing

It’s been an interesting month, to say the least. On July 3, the UK Government caused great confusion within the specialty by stating that ‘beauty salons’ were to remain closed, clarifying that this includes any premises providing ‘cosmetic, aesthetic and wellness treatments’.1 Just a few days later, the Government acknowledged there is a difference between medical aesthetics and beauty for the first time in history.2

The Department of Health and Social Care (DHSC) provided a statement to the British Association of Cosmetic Nurses (BACN), the British College of Aesthetic Medicine (BCAM), Save Face and the Joint Council for Cosmetic Practitioners (JCCP) clarifying that its COVID-19 regulation on remaining closed from July 4 did not apply to medical aesthetics.2 Throughout the COVID-19 pandemic, the All-Party Parliamentary Group (APPG) on Beauty, Aesthetics and Wellbeing has been active in liaising with the Government regarding the reopening of the industries.3 However, members of the medical aesthetic community have voiced concerns with the AAPG representing the specialty.

About the APPG An APPG is a politically neutral cross-party group of Parliamentarians who are concerned about a particular issue; in this case, beauty, aesthetics and wellbeing. This APPG aims to promote, support as well as challenge the beauty industry in Parliament through regular meetings, and provide a platform that highlights and celebrates the industry.

The group states that it also aims to provide a forum that explores the challenges impacting the industry, facilitating discussion, debate and action to overcome such issues.

The APPG Parliamentarians include co-chair Carolyn Harris MP, co-chair Judith Cummins MP, vice chair Alberto Costa MP, vice chair Jessica Morden MP, vice chair Jackie Doyle-Price MP, treasurer Peter Dowd MP, secretary Nick Smith MP, and honorary member and former MP Jenny Chapman.

The secretariat is run by public affairs consultancy firm Interel Consulting UK, which has experience in lobbying, and is funded by the National Hair & Beauty Federation (NHBF).4,5

Recent activity

The APPG has been particularly active during recent months through COVID-19,6 and in the leadup to the July deadline of its call for evidence for its inquiry into UK non-surgical cosmetic procedures.7 This inquiry aims to review the scope and scale of botulinum toxin or similar anti-wrinkle injectables, dermal fillers, polydioxanone (PDO) threads and PDO cogs. It also looks to assess the adequacy of the regulatory and legislative structures and training around non-surgical cosmetic treatments in the UK, review the case for registration of practitioners, and consider the media and consumer environment for products.7,8 Following the inquiry, the APPG states that it will present a report to Government with recommendations for how to ensure necessary and professional standards are in place. Harris and Cummins said, “We are seriously concerned by the complete lack of robust, consistent and enforceable standards for undertaking treatments such as toxin and fillers. To make matters worse, there is no accountability or consequence for malpractice.” They added, “While the aesthetics industry continues to grow at a rapid pace, the absence of standards leaves practitioners with no support and customers with no guarantee of safety. We look forward to hearing further evidence in our inquiry on what action must be taken to address these issues. The Government has a duty to take action which is long overdue.”

Concerns from the medical aesthetic community Aesthetics has been made aware of a number of concerns raised by medical aesthetic practitioners in regards to the APPG. The concerns have been spearheaded by aesthetic practitioners Dr Tapan Patel and Dr Steven Land, who have sent a letter on behalf of medical professionals in the field to the Secretary of State for Health and Social Care, Matt Hancock MP. The letter had just under 700 signatures of support from medical aesthetic doctors, dentists, nurses and surgeons.9 Dr Patel says that although he and his colleagues welcome the APPG’s recognition that there needs to be improved standards around non-surgical cosmetic procedures, they believe there needs to be strict limitations to those with medical, dental or nursing degree, as the bare minimum. He explains, “We strongly object to the grouping together of the beauty industry and aesthetic medicine. The two may be associated but there are clear distinctions and we propose that these

distinctions be made clear in law.” He explains that there are significant differences between the aesthetic medicine field and the beauty industry. “Aesthetic medicine is performed in healthcare facilities. Beauty therapy is conducted in salons. Medical aesthetic clinics have patients, beauty salons have clients. The practices of medicine, dentistry and nursing are professions requiring a university degree. Applicants need to fulfil entry criteria, be selected by an institution, undergo training and then have the option of specialisation. Aesthetic medicine is one such field and is NOT an industry,” he voices.

Another prime concern raised is the APPG’s funding. Dr Patel says, “Interel Consulting UK has been paid by the NHBF to act as secretariat. This is a huge conflict of interest.” He explains that he and his colleagues believe the conflict is particularly apparent in the circumstance of the APPG’s inquiry, as the NHBF appears to support members of the beauty industry injecting fillers and toxin.10,11,12

Among other points, Dr Patel and Dr Land are proposing to separate the APPG into two distinct entities; one for aesthetic medicine and one for the beauty industry. They also want to introduce and protect by law specific terminology that distinguishes treatments performed by a healthcare professional and those done by the beauty industry, ensuring that aesthetic treatments like toxin, threads and fillers can only be performed by a medical practitioner.9 As well as sending the official letter to Matt Hancock, Dr Patel and Dr Land have also submitted their concerns and evidence into the APPG’s inquiry on behalf of 20 of their colleagues.

Thoughts from the associations

Aesthetics spoke to associations within the medical aesthetic specialty to hear their thoughts on the APPG.

Sharon Bennett, chair of the BACN, said, “In this unregulated field, the APPG is doing the right thing by looking at making the aesthetic profession safer and I applaud that they are reviewing education, training and products.” She adds, “However, it appears that the APPG lacks insight in that injectable aesthetic treatments and other high-risk aesthetic treatments are medical procedures which, at the most basic level, warrant an initial qualification to that of other medical specialties. The BACN does not support non-medical injectors because the dangers to patients are too great, they do not have the ability to medically assess nor understand underlying medical conditions, health or medications, and are not accountable to a statutory regulator.”

The BCAM states that the Board has provided a detailed submission to the group’s inquiry into non-surgical cosmetic procedures and provided passionate oral evidence from Dr John Curran, past president of BCAM, at the most recent evidence hearing on July 7.8 The BCAM said in a statement, “The preponderance of non-medical beauticians engaged with APPG underscores the importance of the doctors and dentists of BCAM being the ‘go-to’ body for information, advice and guidance on medical aesthetics.”

Clinical director of Save Face and aesthetic nurse prescriber, Emma Davies, stated, “Save Face cannot fault the intention and shares the concerns and frustrations of the APPG. However, with the greatest respect for any individual or organisation attempting to do something constructive to affect positive change, there needs to be a clear understanding of the political, policy and legislative process. Save Face does not feel the APPG is an effective platform to achieve the very specific goals the specialty needs as voiced by Dr Patel.”

Aesthetics approached the APPG with the concerns raised and received the following response from APPG Secretariat Louise Abraham, “The APPG on Beauty, Aesthetics and Wellbeing is a cross-party group of Parliamentarians. The Group is run by and for the Parliamentarians, who consult a range of external organisations. All views expressed are those of the Group. The Group launched its inquiry into non-surgical cosmetic procedures to investigate how standards for undertaking treatments such as botulinum toxins and dermal fillers can be improved to protect public safety. Members of the APPG have heard representations from both medical and beauty practitioners to better inform the findings of the inquiry, with a view to raise standards for all in the industry.” The APPG did not respond to specific questions regarding its funding and concerns with combining ‘aesthetics’ with ‘beauty’ in the wording of the group.

The future of medical aesthetics

Dr Patel believes that now is the time to lobby the Government for regulatory change. “It is vital the Government take action now or it may seem to be complicit in the next complication caused by a lay injector. Having a cosmetic procedure should be an informed decision but the availability of the procedures is getting uncontrollable. It is not too late to act now, but we do lose precious time with every passing day,” he says. Conversely, Davies isn’t so sure that now is the right time for change. “Currently, the Government and policy makers have been consumed, first by BREXIT and now, by a global pandemic. Is now the best time to insist Government address this complex issue and the legislation we require? We must look at the steps we can take ‘in-house’, to change public perceptions and influence public choices. We must focus on establishing a very clear distinction between beauty aesthetics and medical aesthetics. We need to gain more respect, by earning more respect.”

Bennett also acknowledges that there is much the medical aesthetic community needs to do to ‘clean up the industry’ before the issues raised will be taken seriously by Government.

She says, “Although we are medical professionals delivering medical treatments we must, as a community, demonstrate the seriousness of these medical procedures which has sadly been lost over the years by many medical professionals working outside of medical settings. The ideal would be to work collectively in medical/clinical settings moving away from other models of practice. This will, in time, shift public perception and normalise the delivery of these treatments back where they belong into the safe hands of medically-qualified accountable professionals, with the ability to manage complications in clinical settings.”

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