A MEMBER EVENTS & SEMINARS COLLEGES & TRAINING APAA AWARDS ACCREDITED SALONS HEALTH & BEAUTY FACTS IMPORTANT LINKS
Injections in Appearance Enhancement
Protocols and Who
Can Deliver Them?
We are all familiar with the love affair women have with Botox and Restylane or any procedure that can deliver a quick result when it comes to plumper, fuller lips or instantly removing frown lines and fine wrinkles. The virtues of these soft-option procedures are usually administered through injections.
These services can be performed both in a doctor's surgery or a beauty clinic, but who is allowed to perform these procedures from a legal and an insurance point of view?
On a regular basis the APAA receives phone calls from therapists and makeup artists who wish to introduce these services to their clients, but would like to provide the service themselves. They argue that other countries allow Botox and Restylane to be delivered by non-medical practitioners, so why shouldn’t we? However, as professionals we are obligated to abide by our own laws and regulations.
Botox and Restylane are classified as Cosmetic S4 injection drugs and can only be administered by a doctor or by a registered nurse who is supervised by a doctor. This is important for therapists to know, particularly if they allow a nurse to administer these procedures in their salon.
Several months ago the APAA received a letter from the Cosmetic Physicians' Society of Australasia (CPSA) stating that a recent investigation by the NSW Health Care Complaints Commission (HCCC) regarding inappropriate delegation of Cosmetic S4 injections to nursing staff was bought to their attention.
It was discovered that a doctor failed to supervise nursing staff performing S4 Cosmetic injections. He did not see and consult with patients and prescribe medications prior to nurses performing the injections. The HCCC consulted the NSW Medical Board during the investigation, resulting in the matter being finalised by the HCCC making adverse comments to the doctor under s.30 (1) of the Health Care Complaints act.
The letter went on to say that there are strict guidelines for the prescription and administration of S4 medicines. The CPSA was aware that delegation of cosmetic S4 injections to nursing staff is a common practice in many plastic surgery rooms and that these guidelines may not always be followed. The CPSA expressed concern that nurses who administer S4 medicines with no prior prescription may be at risk of losing their registration.
As a result the CPSA has developed a protocol for delegation of S4 injections. The NSW Medical Board has stated that this protocol is essentially consistent with the Board's Code of Professional Conduct and that it contains additional details, specific to cosmetic practice. The Board also stated that the draft protocol sets out a sensible set of circumstances in which medical review should be sought. A copy of this protocol was enclosed and we were encouraged to present this protocol to our members to ensure that they are protected from complaints similar to the ones mentioned in their letter.
Below is the information they provided and we would urge all salons who wish to provide this service in their salons to be made aware of these standards, particularly if they wish to use a nurse to deliver these treatments.
PROTOCOL FOR DELEGATED COSMETIC S4 INJECTIONS
Suitably trained registered nurse may administer S4 medicines for cosmetic purposes after a doctor has consulted face-to-face with a patient and formulated a written treatment plan:
1. To cover a time period no greater than a year
2. Stipulating the area to be treated
3. Stating which medications are to be used
4. Setting the maximum number of procedures
5. Stating the maximum dosages of the medication to be administered.
The patient and treatment plan would be reviewed:
1. At the expiration of the set time period
2. If unexpected side-effects occurred
3. If the patient or nurse were unhappy with the result
4. If new indications for the ordered medications were contemplated
5. If other medications were considered for the original or new indications
6. If the original presentation were altered by e.g. surgery, trauma, pregnancy or other procedures for which the original treatment plan did not cater.
If the patient were taking new medications the nurse would need to check with the supervising doctor prior to the procedure to ensure there were no contraindications to proceeding with the treatment plan.
Suitably trained registered nurses may perform such procedures at adequately equipped premises, distant from the doctor's rooms only if treatment plans for all patients had previously been formulated by the supervising doctor, following a face-to-face consultation. The doctor should be readily contactable, but need not be on site.
It is not acceptable for a doctor to on-sell S4 medications to a nurse or other person to then administer these to patients, regardless of any prior order for the administration of said medications.
Registered nurses performing such procedures must:
1. Have current registration in the relevant State or Territory
2. Be covered by the practice insurance policy. In the case of an independent contractor they must have his or her own insurance policy
3. Have had adequate training in the particular procedure/s
4. Be certified as competent where certification exists, or deemed competent by a trainer approved by the supervising doctor.
The CPSA stated that they do not endorse the use of injectors whose qualifications or experience is less than that stated above and they are vehemently opposed to injections being given by non-medical persons such as beauty therapists. All involved must ensure that they also adhere to any additional requirements pertinent to their own State and Territory, which must be fulfilled.
Several beauty therapists have indicated that we should pursue to include the above procedures within our Dermal Science Degree program, so that ultimately aesthetic therapists can be qualified to perform these treatments to their clients. However, at this stage this has not been achieved. It is a milestone that has as yet to be conquered.