The Cosmetic Surgery industry is now estimated to be worth over £2.3bn in the UK. It exists almost exclusively in the private sector and hence there is a significant commercial influence. That commercial influence makes profit margins of utmost importance and the overriding concern of the business. That, in my view, is in conflict with the ethics of best care in medicine. In my previous blog, “Cosmetic Surgery – Commercialism Vs Ethics – Should There Be More Regulation?”, I set out the foundations as to why more regulation was required in my view and why the cosmetic industry is sometimes thought to take advantage of vulnerable people, often via compelling advertising and reduced prices for limited periods.
Following the PIP faulty breast implants scandal in 2011 the government commissioned a review of “cosmetic interventions.” The review was chaired by Professor Sir Bruce Keogh, an NHS medical director, famed for his previous reviews requiring significant budget cuts to be implemented in the NHS. I was cynical as to whether his approach would exhibit a different attitude in the non-NHS i.e. private sector. He says better regulation and protection is needed for consumers of cosmetic surgery. Those are easy, and obvious, words to say but will implantation of the review result in improvements in the delivery of services for consumers?
The review has identified some fairly obvious features of the cosmetic industry and missed others that I believe are shouting out for regulations.
Obvious points commented by review:
- There is huge media pressure driving women to plastic surgery. Correct. But statistics show that plastic surgery is no longer an all-female issue
- There is particular concern over the so called cosmetic injectables (e.g. anti-wrinkle treatment) that is presently unregulated and can be administered by anyone on a commercial basis. He proposes such items will become prescription only. The report deals with the fact that there is no regulation or quality testing in the manufacture of these chemicals. He proposes that beauty therapists should only be permitted to administer such injectables once they have been appropriately trained.
- There is no specialist cosmetic surgery register. This is to change and standard will be set and implemented by the Royal College of Surgeons (RCS) who will create a committee on cosmetic surgery. It will include regulation of beauty therapists who will have to be accredited.
- Complaints. There is presently no effective avenue for complaints or measuring of adverse trends in the industry and it is proposed that this be remedied with the creation of an ombudsman.
- A Registry should be established for “devices” e.g. implants that can monitor safety and allow recalls for faulty products.
- Existing advertising recommendations and restrictions should be updated and better enforced. The use of financial inducements and time-limited offers to promote cosmetic interventions should be prohibited to avoid inappropriate influencing of vulnerable consumers. This is to be implemented by the RCS Interspeciality Committee who will develop a code of ethical practice.
Obvious points not commented upon by review:
If I want a cosmetic procedure I can self-refer to a surgeon and s/he can agree to perform the procedure without reference to my previous medical records. Surely that is a fundamental issue that should be challenged in order to increase patient safety? The English healthcare system is based upon the patient having a general practitioner who co-ordinates care and provides a “safety net” looking for contra-indications and complications. Without that, how can these proposed reforms be optimally effective?
The review opines “Previous attempts at self-regulation in the industry have failed, largely because ………..only the best in this disparate sector commit themselves to better practice whilst the unscrupulous and unsafe carry on as before”. It also stated “It is our view that dermal fillers are a crisis waiting to happen.”
So, set against an acknowledged backdrop of an industry motivated more by financial gain than by quality care, will the reform actually make a difference? Only time will tell, once implementation details are unveiled. In my view this is a huge step in the right direction, but as ever the “devil is in the detail” and that is yet to be unveiled. Without the detail the level of enforcement and effectiveness of enforcement cannot be analysed.