Who may legally inject

5.1.1The assumption people arrive with

Almost everyone assumes that putting a needle into a face for cosmetic purposes is restricted to healthcare professionals. It is a reasonable assumption. It is not, for this category, an accurate description of the position in England.

The confusion arises because two different injectable treatments occupy the same clinics and the same conversations. Botulinum toxin is a prescription only medicine, so it must be prescribed by a prescriber who has assessed the patient, and the supply chain is controlled by medicines law. Dermal fillers and other injectable devices, including polynucleotide products, are not medicines. The framework that restricts who may handle a prescription only medicine simply does not reach them.

5.1.2What a qualification means, and does not

Practitioners in this sector hold a wide range of things described as qualifications, and they are not equivalent.

• A healthcare registration. Doctor, dentist, nurse, midwife, pharmacist, or a profession regulated by the Health and Care Professions Council. This means a public register, a code of practice, a fitness to practise process, and a regulator you can complain to. It does not by itself mean training in aesthetics.
• An accredited aesthetics qualification. Awarded by a recognised body against a defined standard. Meaningful, and worth asking which body and which level.
• A training course certificate. Ranging from substantial to a single day. Frequently provided by, or connected to, the company selling the product.
• Membership of an organisation. Some membership bodies set entry standards and hold members to them. Some do not. Ask what the entry requirement was.

The distinction that matters most to you is the first one, because it is the one that gives you somewhere to go if something goes wrong. A practitioner on a healthcare register is answerable to that regulator. A practitioner on no register is answerable to nobody in the professional sense.

5.1.3How to check, in five minutes and free

Every healthcare regulator in the United Kingdom maintains a public register that you can search by name. Ask your practitioner which register they are on and what their registration number is, then check it yourself. This is not an insult and it takes very little time.

• Doctors: the General Medical Council register.
• Nurses and midwives: the Nursing and Midwifery Council register.
• Dentists and dental care professionals: the General Dental Council register.
• Pharmacists: the General Pharmaceutical Council register.
• Other regulated professions: the Health and Care Professions Council register.

What you are checking is that the person exists on the register, that the registration is current, and that there are no restrictions recorded. All of that is public information and it is published precisely so that patients can look at it.

5.1.4Voluntary registers

The Joint Council for Cosmetic Practitioners maintains a voluntary register of practitioners and of education providers in the non surgical cosmetic sector, and publishes standards. Voluntary means what it says: nobody is obliged to join, and being absent from it is not evidence of anything. Being present on it means somebody has checked something, which is more than the baseline.

Professional associations including the British Association of Dermatologists and the British Association of Aesthetic Plastic Surgeons publish patient guidance and represent particular medical specialties. They are useful sources of general information and they are not registers of everyone offering these treatments.

5.1.5The position is not the same across the UK

Health regulation is devolved and the picture differs. In Scotland, independent clinics where a treatment is provided by certain regulated professionals fall within the regulation of Healthcare Improvement Scotland. In Wales, Healthcare Inspectorate Wales regulates independent healthcare. In Northern Ireland, the Regulation and Quality Improvement Authority does. In England, the Care Quality Commission regulates certain regulated activities, and a great deal of non surgical cosmetic practice falls outside them.

The practical implication for a patient is simply that the answer to whether the premises are inspected by anyone depends on where you are and who is treating you, and it is a fair question to ask directly.

5.1.6What to ask, and what a good answer sounds like

• Are you on a healthcare register, which one, and what is your registration number?
• What training have you had specifically in this treatment and this area?
• Who provided that training, and was it connected to the company selling the product?
• Is this practice registered with or inspected by any regulator?
• Do you hold medical indemnity insurance covering this procedure, and with whom?
• If something goes wrong outside clinic hours, who do I call?

A good answer to all six takes under two minutes and is given without hesitation. The value is not in any single answer but in whether the practitioner treats these as ordinary questions that patients ask, which is what they are.

5.1.7In fairness to non medical practitioners

It would be easy to read this article as saying that only doctors should inject. That is not the position it takes. There are experienced non medical practitioners in this sector who train continuously, work to a high standard, refer appropriately and have better outcomes than some registered professionals who inject occasionally.

The point is narrower. Registration is not a guarantee of skill, but it is a guarantee of accountability, and accountability is the thing a patient cannot verify for themselves. In a sector where anyone may legally offer this treatment, knowing whether the person in front of you is answerable to anybody is the single most useful piece of information available, and it is free to obtain.