BAPRAS responds to Department of Health's review of regulation on cosmetic interventions

The Department of Health has published its Review of Regulation on Cosmetic Interventions.  BAPRAS, the professional association representing plastic, reconstructive and aesthetic (cosmetic) surgeons on behalf of the Royal Colleges, has supported the review process since the PIP Implant Crisis in December 2011.

Tim Goodacre, Chair of BAPRAS' Professional Standards Committee Review’s Working Group on Training and Education in Cosmetic Surgery, said:

“The range of cosmetic interventions that are available has increased exponentially over the last few years and, as rightly identified by the review process, the current regulatory framework is not protecting individuals, particularly vulnerable groups, from bad and often inappropriate practice.  This is a strong series of recommendations and we are pleased that many of our priorities have been included.  We hope they achieve Parliamentary approval and support quickly so that the detailed implementation work can begin and patients can be sure of high quality care and controlled outcomes at all times.”

Commenting on the proposals for surgical interventions in more detail, he said:

“Quite rightly, the recommendations focus on patient protection by ensuring that the only practitioners able to undertake surgical procedures are on the GMC Specialist Register and are practicing within their specialty.  We will work closely with the Royal College of Surgeons and other interspecialty groups to support the creation of consistent training and practice for cosmetic surgery specifically and, as this is created, urge patients to actively review the GMC Register before they commit to any procedure.

“The drive to make outcome data available from all practitioners is important and we are pleased to hear the recommendation that – for the first time - private providers are mandated to collect and share data as a prerequisite for CQC registration.  As an association we are already working closely on the creation of consistent outcome measures across the plastic surgery discipline and we believe these learnings will be helpful for the creation of cosmetic surgery specific outcomes.  What is critical is that patients have access to meaningful data sets wherever they choose for procedures"

“We strongly support the recommendation that a register for implantable devices is created and that this starts with breast implants.  We know that one of the difficulties for registers is getting patients to take part and urge the use of an ‘opt-out’ mechanism to drive uptake. We are working closely with the Australian Society of Plastic Surgeons who are already operating a best practice breast implant register and propose that this acts as a strong starting point for the UK.

“Underpinning the creation of a new regulatory framework for cosmetic interventions is an informed and empowered public who are able to make active and informed choices.  BAPRAS has consistently provided consumer information to enable careful consideration of procedures and wholly agree that consent processes must be used for both surgical and non-surgical procedures.  We are very pleased to note the recommendation that proposes prohibition of financial incentives for any cosmetic intervention and a tightening of advertising codes of practice overall.

“We support these recommendations and, as soon as they have received Parliamentary approval, will work closely with all relevant parties to turn them into reality. We hope that this will happen as quickly as possible so the safety and wellbeing of patients can be assured.”

BAPRAS President Graeme Perks is currently in Australia discussing an international consensus for an agreed minimum dataset for breast implant and device registries with other international societies of plastic surgeons.  Known as ICOBRA - International Collaboration of Breast Registry Activities - this will build on best practice which is currently operating in Australia.

Summary of BAPRAS priorities for future regulation of Cosmetic Interventions:
Information, consent & advertising
•  One clear set of rules relating to cosmetic surgery advertising with decisive action taken against practitioners who break the rules
•  Statutory protection across all forms of media to prohibit any form of financial incentive and any promotion to under 18s
•  Accurate use of language with number of years practitioners have been on a specific GMS Specialist Register as the only objective measure of experience and a ban on terms ‘leading’ or ‘expert’

Regulation of practitioners
•  Practitioners who use the term surgeon in their title must be on the GMC Specialist Register and work within the defined scope of practice for their designated specialty
•  Cosmetic surgeons should be trained via the NHS and have appropriate mentoring programmes when they establish independent practices
•  ‘Fly in/Fly out’ visiting surgeons must be subject to exactly the same standards and regulations as UK surgeons, and healthcare providers must be able to prove that such surgeons have validated assessment of surgical competence / ability

Regulation of providers
•  Private providers of cosmetic surgery must adhere to the same code of conduct and standards as those expected of the NHS, including mandatory reporting of procedures undertaken
•  Provider institutions need to be subject to robust regulation through active inspection and enquiry. There should be an annual reporting mechanism to the agreed regulator, who should at all times have the expertise and authority to act in the public interest
•  Private cosmetic surgery providers must be made responsible for the aftercare of their patients, regardless of the timeframes in which the interventions took place.  This is likely to require a system to support patients affected by provider bankruptcy

Medical implants, devices and other products; data and registries
•  A national, compulsory register for medical devices including breast implants must be developed
•  Improved surveillance of breast implants and other cosmetic devices must be conducted in order to ensure poor quality products are recognised and dealt with early
•  All injectable materials need to be registered as medical devices and CE marked, including both absorbable and permanent fillers, to ensure they are subject to the appropriate regulatory procedures
•  All practitioners using fillers and toxins by injection must maintain full records of treatments and record outcome data to a standard that can be audited independently