Review of the Regulation of Cosmetic Interventions- BAPRAS Feedback

BAPRAS exists to support the highest levels of practice within plastic and aesthetic surgery, for the benefit of the whole population. We have patient interests at our core, and seek to maintain best practice through education and training, standard setting, high quality information development, and research into better care in its’ widest sense.

We therefore warmly welcomed this review and we look forward to hearing what changes will be proposed when Sir Bruce announces the results in March 2013.

The review covers a large number of issues associated with cosmetic surgery and procedures, and we are very supportive of the chosen focus areas – they are entirely in line with our own commitment to developing and improving the highest standards of care.  Here below I summarise a few key areas of feedback that we have provided to the review committee:

Overview
•  Majority of Cosmetic Surgery procedures are demanding in technique, judgement, and patient management and cannot be practiced safely without extensive training including extensive preliminary observation and rigorous training that cannot be encompassed in short courses.   
•  Cosmetic Surgical procedures are frequently trivialised by mass media and marketing organisations.

The surgeons and practitioners
•  Should have Specialty Fellowship examination standard before subsequent sub-specialty training in cosmetic operations.
•  Should be on GMC Specialist Register in their respective parent specialty.
•  Should only perform operations within the acknowledged remit of their parent specialty (for example, ENT surgeons could do nose reshaping, but should not do breast or abdominal surgery etc).
•  Overseas doctors entering UK with only basic medical qualifications and no UK validated assessment of surgical competence / ability should not be permitted to operate independently. This practice should stop immediately.
•  All practitioners using fillers and toxins by injection should be required to maintain full records of treatments and record outcome data to a standard that can be audited independently. They should also be able to demonstrate appropriate training in the field, which cannot be undertaken in short day courses as currently encountered.

The Provider Institutions
•  Should be required to participate and maintain full data on who does what, where, and how well within their institution. This would require full cooperation with a centrally supported data collection mechanism that BAPRAS has urged be developed, to be hosted within the Royal Surgical Colleges/Specialty Association structure.
•  Should be mandated to provide appropriate systems to support patients with unexpected adverse events after surgery, some of which are inevitable in every area of care. This is not currently the case when commercial imperatives are allowed to take precedence over good patient care.
•  Must be transparent in all areas of case management alongside regular and rigorous auditing of outcomes.
•  Must participate in the 'ABTA-style' proposal to support patients affected by provider bankruptcy (within the DH review document) if it is developed. However, BAPRAS believes that much more common is poor or frankly negligent aftercare for procedures from practitioners and providers which would not be covered by such arrangements.

Advertising
•  A significant proportion of those seeking cosmetic surgery fall within a 'vulnerable' category, and should be protected from unreasonable promotion of procedures which can be trivialised, and subtly promoted as delivering objectives far beyond what can be considered realistic.
•  BAPRAS has serious concerns about current state of advertising of cosmetic procedures in the UK. The fine line between informing and persuading is frequently transgressed, and abuse of advertising and thinly veiled promotion in supposedly 'educational' features is widespread.
•  We urge a rapid and rigorous review of the regulations surrounding advertising of cosmetic procedures, with especial attention paid to on-line material which is largely unregulated.
•  We would like the establishment of an 'Ofcom' style organisation to manage concerns around poor compliance with better and speedier action. We would like to see the ASA sanctions strengthened to enable control of individual websites which contain misleading information, unreasonable persuasion, and erroneous presentation of credentials.
•  We believe that self regulation by the 'industry' at present has failed (despite the existence of the IHAS code of practice) and urge that advertising in future is co-regulatory rather than self-regulatory according to the ASA rules.

Materials and devices
•  All injectable materials (fillers both absorbable and permanent) should be registered as pharmaceutical products, and subjected to the full gamut of regulations as such. This would bring the UK into line with normal practice in the United States under FDA law.
•  Breast Implants should be registered, with an 'opt out' mechanism of presumed participation by all patients and providers unless specifically requested.
•  BAPRAS urges consideration of the well-developed system suggested by the Australian Society of Plastic Surgeons, which recommends collecting a basic dataset across international boundaries to improve rapid detection of problems that might present with any device.

We continue to work closely with the Government to provide guidance on ensuring the highest standards of plastic surgery safety and care, including developing training, standard setting, ongoing education, and research into better practice.
I look forward to updating you on any recommendations emerging form this review in due course.

Tim Goodacre
Chair, Professional Standards, BAPRAS