Chair of the JCCP Professor David Sines explains how the organisation hopes to enforce protection and safety of patients through its Code of Practice.
About the JCCP
The Joint Council for Cosmetic Practitioners (JCCP) is a UK registered charitable body, which is accredited by the Professional Standards Authority (PSA)1 in recognition of our declared aim and standards which are designed to protect the public through:
The JCCP is an independent charitable organisation that is accountable to an established board of trustees.2,3 The JCCP was launched at the House of Lords alongside its sister body, the Cosmetic Practice Standards Authority (CPSA) in February 2018.4
The charity's objectives make reference to the promotion of the health and safety of, and protection of the public by the development and implementation of high standards of performance and practice among non-surgical cosmetic practitioners and hair restoration surgeons.3 This includes the definition, creation and maintenance of an effective structure to inform the standard of professional education and training amongst non-surgical cosmetic practitioners and hair restoration surgeons.
This objectives includes working with professional regulated statutory bodies that are engaged with non-surgical cosmetic practice to agree appropriate processes for joint working with regard to fitness to practice and registrant conduct, informed by the standards of practice proficiency and safe practice set down by the JCCP.
The JCCP also provides knowledge and advice to stakeholder bodies and organisations responsible for developing and maintaining clinical and practice-based standards for cosmetic/aesthetic treatments to ensure public safety. The JCCP will achieve this through the maintenance of a voluntary register of persons who are fit to practise as non-surgical cosmetic practitioners and hair restoration surgeons and who have met prescribed criteria and continuing professional development requirements set by the Council. The JCCP has also published, operates and enforces a Code of Practice for its Registrants in the interests of public protection.5
The JCCP and CPSA Code of Practice
The JCCP and CPSA have co-designed and published a guidance document in the form of an agreed ‘Code of Practice’ that relates specifically to those practitioners carrying out cosmetic interventions.5 ‘Cosmetic interventions’ means any intervention, procedure or treatment carried out with the primary objective of changing an aspect of a patient’s physical appearance, and includes cosmetic procedures, both invasive and non-invasive (including hair restoration surgery). These guidelines should be seen as ‘best practice’ for cosmetic practitioners as mandated by the JCCP and CPSA and not as being legally enforceable by statute.5
The JCCP and CPSA acknowledge that cosmetic interventions can have significant positive and negative impacts on the health and wellbeing of patients. There have been major concerns in the media, the public and the professions about patient and public safety, and whether the sector operates in an ethical manner. To that end, it is fundamental that all practitioners have the right skills, practise at a level appropriate to their qualifications and experience, and that they ensure that products used are clinically validated and appropriately licensed. The JCCP also requires that its registrants ensure that patients receive accurate information, as well as experiencing a thorough consultation and consent process before deciding to undergo a cosmetic intervention.
The Code of Practice is based on the assumption that any practitioner who undertakes cosmetic treatments is embarking on a new career pathway, associated with significant risk of harm to patients and members of the public. The JCCP has therefore introduced a range of fitness to practice procedures that are designed to promote best practice within the sector and to set out guidelines appropriate to all levels of practitioners as to the risks involved and how to mitigate them, alongside the implementation of sanctions if required. These procedures apply to all aesthetic practitioners, regardless of level of attainment or professional background. These procedures (and their associated sanctions) apply equally; therefore, they apply to those cosmetic practitioners who are registered clinicians, as well as to those who do not have registerable status with a professional statutory regulatory body (PSRB) and who perform procedures that the JCCP formally recognises and has agreed to register. Our aim is to give a practitioner a sense of belonging to this applied area of practice and to outline the duty of care that they should provide to the public and to other practitioners.
The guidelines were developed following a wide-ranging consultation process of those involved in the provision of cosmetic treatments. In addition, where appropriate, the guidelines incorporated advice included in guidelines issued by PRSBs such as the GMC, NMC, GDC, HCPC, GPhC and PSNI. However, this guidance does not replace the requirement for clinicians registered with any PRSB to comply with their overarching obligations to that body. If, however, this guidance covers areas not included by their PRSB, the JCCP mandates that this guidance must be followed by JCCP registrants in addition to that of their PRSB.
The Code of Practice also requires all practitioners who provide cosmetic interventions to perform an audit annually and engage in either statutory or non-statutory appraisal/peer review and supervision, revalidation and/or CPD activities that are prescribed by the JCCP, without which patient safety cannot be assured.5
Aims of the Code of Practice
In summary, the Code of Practice has been produced to ensure that practitioners:5
The key responsibilities cited in the Code of Practice require registrants who offer cosmetic interventions to:5
The JCCP’s approach to fitness to practise
The over-arching aim of the JCCP in exercising its functions is the protection of the public and to:8
To exercise its responsibility to protect the public, the JCCP has enacted rigorous admission criteria that govern access to the Practitioner Register, which is divided into two separate parts:9
1. Part One for Clinical Processionals who are registered currently with a Professional Statutory Regulatory Body (PSRB)
2. Part Two for those persons who are not registered with a PSRB. The JCCP applies the same standards of expected practice to both parts of this register
The Code of Practice referred to above forms the basis for the determination of the Council’s expected standards of professional conduct, supplemented by a registrant’s acceptance and adherence to the CPSA Practice Standards that relate to their specific modality/level and area of applied practice and evidence of their compliance with JCCP mandated educational and good character standards. Together these form the ‘standard test’ against which the Council will determine a registrant’s ‘fitness to practise’ and standard of professional conduct.
The JCCP operates an open and transparent process with regard to its fitness to practise procedures. Robust systems and procedures have been developed and implemented to ensure public protection that include the following:8
Partnership with other professional regulatory bodies
One of the JCCP’s stated key objectives has been to establish effective working relationships with the health-related PSRBs that provide statutory regulation within the sector. The JCCP is continuing to work closely with relevant healthcare PSRBs in order to enhance public protection, to reduce unwarranted variation in care/procedural delivery and to reduce the risks that are associated with unsafe practice. In this regard, the JCCP has entered into separate Memoranda of Understanding (MoU) with the General Medical Council, the General Dental Council, the Nursing and Midwifery Council, and with The General Pharmaceutical Council.10-13 These four separate MoUs set out a framework between the JCCP and each of the above cited PSRBs to ensure that:
The four separate MoUs relate to the areas of interface between the designated PSRB and the JCCP, but do not affect existing statutory functions or amend any other policies or agreements relating to the activities of the PSRB and the JCCP. However, the PSRBs and the JCCP have set out a framework to support a productive working relationship between the respective organisations and to cooperate to deliver and (wherever practicably possible) adhere to the following principles that are set out in our shared MoUs:10-14
The JCCP has also exchanged letters of cooperation with the Health Care Professions Council (HCPC) to enable the sharing of information regarding complaints relating to fitness to practise issues that might be drawn to the JCCP’s attention when regarding aesthetic practice undertaken by HCPC Registrants.
First and foremost, the JCCP recognises and respects the statutory function that these Council’s transact and has declared to work closely with each Council in furtherance of their statutory function without compromise to the independence that they and the JCCP possess with regards to their status, role and function. However, we also acknowledge that we share a common endeavour in our quest to protect the public by at all times respecting public trust and confidence and by promoting best professional practice in the interests of patient safety.
In this regard, the JCCP was privileged to engage with professional statutory regulators to enable open dialogue to be established during the formative stages of the Council’s evolution and establishment. Furthermore, the JCCP has incorporated best practice guidelines provided by the PSRBs in the area of cosmetic practice into its own Code of Practice and has modelled its Fitness to Practice rules and procedures on those currently transacted by the professional regulators. These rules have been formally sanctioned by the PSA.
The JCCP has also signed a MoU with The Royal Pharmaceutical Society (RPS)14 to establish a collaborative partnership between the RPS and JCCP to encourage safe and professional aesthetic practice by aesthetic pharmacists. The key objectives of this partnership are to:
Governance and the JCCP practitioner register
The JCCP has established a formal Practitioner Register Committee that will oversee and manage exclusively the Council’s Practitioner Register and all associated Fitness to Practise Committee processes. The Committee is chaired by Professor Mary Lovegrove OBE. The JCCP is committed to the promotion of patient safety and public protection and considers that the endorsement of its fitness to practice procedures by the Professional Standards Agency provide endorsement of the processes that the JCCP has embedded within the context of its governance and constitutional frameworks.
1. PSA accredits JCCP, Aesthetics, 2018. <https://aestheticsjournal.com/news/psa-accredits-jccp>
2. Kilgariff, S, The Future of the JCCP, Aesthetics, 2016. <https://aestheticsjournal.com/feature/the-future-of-the-jccp>
3. About Us, JCCP. <https://www.jccp.org.uk/AboutUs/about-the-jccp>
4. JCCP Launch, House of Lords, Aesthetics, 2018. <https://aestheticsjournal.com/news/on-the-scene-jccp-launch-house-of-lords>
5. JCCP/CPSA Code of Practice, JCCP. <https://www.jccp.org.uk/PractitionersAndClinics/jccp-cpsa-code-of-practice>
6. ASA, Advertising Codes, <https://www.asa.org.uk/codes-and-rulings/advertising-codes.html>
7. Joint Statement: JCCP and the ASA. <https://www.asa.org.uk/uploads/assets/uploaded/7888b5d2-a4c6-4f10-8acb534a3dd46943.pdf>
8. About Us – Fitness to Practice, JCCP. <https://www.jccp.org.uk/AboutUs/fitness-to-practice>
9. Structure of the Register, JCCP. <https://www.jccp.org.uk/PractitionersAndClinics/structure-of-the-register>
10. A memorandum of understanding between the JCCP and the NMC, JCCP. <https://www.jccp.org.uk/NewsEvent/a-memorandum-of-understanding-between-the-jccp-and-the-nmc>
11. Memorandum of Understanding agreed between the GPhC and the JCCP, JCCP. <https://www.jccp.org.uk/NewsEvent/memorandum-of-understanding-agreed-between-the-gphc-and-the-jccp>
12. A Memorandum of Understanding between the JCCP and the GMC, JCCP. <https://www.jccp.org.uk/NewsEvent/a-memorandum-of-understanding-between-the-jccp-and-the-gmc>
13. A Memorandum of Understanding between the JCCP and the GDC, JCCP. <https://www.jccp.org.uk/ckfinder/userfiles/files/MOU%20GDC%20JCCP%20011118.pdf>
14. Memorandum of Understanding agreed between the RPS and the JCCP, JCCP> <https://www.jccp.org.uk/NewsEvent/memorandum-of-understanding-agreed-between-the-rps-and-the-jccp>