Cosmetic procedures, including Botox and other anti-wrinkle injections and fillers, will be under the spotlight in an expansion of our year-long crackdown on Australia’s cosmetic surgery industry.

Key points
One year on from the cosmetic surgery review, work is complete on most reforms with higher practice standards and new advertising rules for doctors now in place. Further reforms will focus on the non-surgical cosmetic procedures industry with new guidelines coming for all health practitioners providing these services. Stronger public safeguards are needed because of escalating consumer demand for non-surgical cosmetic procedures and more practitioners seeking a career path in the cosmetics industry.

Key points

One year on from the cosmetic surgery review, work is complete on most reforms with higher practice standards and new advertising rules for doctors now in place.
Further reforms will focus on the non-surgical cosmetic procedures industry with new guidelines coming for all health practitioners providing these services.
Stronger public safeguards are needed because of escalating consumer demand for non-surgical cosmetic procedures and more practitioners seeking a career path in the cosmetics industry.

A year after an independent review into cosmetic surgery provided a foundation to reform the industry, the Australian Health Practitioner Regulation Agency (Ahpra) and the Medical Board of Australia (MBA) are well underway to implement all 16 of the review’s recommendations to improve public safety.

As that work continues, the regulators’ focus is now widening to introduce stronger safeguards for the booming non-surgical cosmetic procedures sector, including new guidelines for registered practitioners performing and advertising aesthetic treatments.

The cosmetic treatment industry estimates Australians collectively spend more than one billion dollars a year on non-surgical procedures ranging from anti-wrinkle injections, fillers and botulinum toxin products such as Botox injections, to fat dissolving injections and thread lifts performed by doctors, nurses, dentists and other health practitioners.

‘Getting these services is not like getting a haircut – these procedures come with risk. We want to ensure the public knows what safe practice looks like, and that practitioners are doing everything necessary to keep the public safe,’ Ahpra CEO Martin Fletcher said.

The number of reported complaints of serious harm from cosmetic surgery has grown significantly since attention was focussed on the sector over the past 18 months. Mr Fletcher said the more frequent use of non-surgical cosmetic procedures, and the expanded range of practitioners who provide them, creates the potential to put a larger section of the community at risk of some harm.

Some recent examples investigated by the regulator include:

Yasmin* is a patient with a history of mental illness who disclosed her history of body image issues and expressed dissatisfaction with the results of 10 previous non-surgical cosmetic procedures. Despite this history, a doctor administered a series of filler injections.
Jennifer* was treated with dermal fillers by a registered nurse, despite having several known skin conditions that made the treatments inappropriate and dangerous. Following treatment, Jennifer had an adverse reaction which required the fillers to be dissolved and steroid treatment to address the reaction.
Amy* underwent intense pulsed light treatment with a doctor to improve the appearance of skin on her neck, but instead suffered significant burns including large purple blistering.
Carly* suffered an infection in her cheek following a botched cosmetic thread lift procedure. Carly’s face became so infected she needed surgery to firstly remove an abscess, and then further surgery to restore her appearance.

Further details of these matters are in the background below.

National Boards will soon be consulting on proposed new practice guidelines for practitioners performing non-surgical cosmetic procedures (excluding medical practitioners who are already subject to the MBA’s Guidelines for registered medical practitioners who perform cosmetic surgery and procedures). Proposed new advertising guidelines will apply to all registered health practitioners advertising non-surgical cosmetic procedures, including medical practitioners.

The planned overhauls are likely to place a stronger emphasis on informed consent and pre-procedure consultation, including a patient suitability assessment. There will also be a focus on prescribing and administering prescription-only cosmetic injectables.

Proposed new advertising guidelines are likely to focus on the use of ‘before and after’ images, claims about expertise and qualifications of practitioners, and affirm the ban on the use of testimonials. There will also be clear rules on the use of influencers and social media figures.

Public consultation on the proposed guidelines will open in coming months ahead of their release in the first half of 2024.

As enrolled and registered nurses perform many non-surgical cosmetic procedures, the Nursing and Midwifery Board of Australia (NMBA) has an established Position statement: Nurses and cosmetic medical procedures released in 2016. This statement provides clear guidance to nurses (nurse practitioners, registered nurses and enrolled nurses) working in or wanting to join the cosmetic sector and was consulted on with key stakeholders.

The NMBA have decided to strengthen this statement into guidelines.

‘The work we have already done in our position statement provides clear advice for nurses working in cosmetics, to ensure public safety. But as the sector grows, now is the time to strengthen our regulatory position and provide further clarity to nurses looking to work and working in this space. The public needs to feel safe and know that nurses performing these procedures are appropriately educated and competent,’ NMBA Chair Veronica Casey AM, said.

Since the Independent review of the regulation of medical practitioners who perform cosmetic surgery was released on 1 September 2022, work to implement all 16 recommendations has advanced with most now complete. Strengthened practice guidelines and new advertising guidelines for medical practitioners doing cosmetic surgery are in place, along with a registration standard to create an endorsement for cosmetic surgery.

‘We are already seeing a positive impact from strengthened practice and new advertising guidelines in the industry, and we are pleased that most practitioners have worked constructively with us towards these reforms. The endorsement for cosmetic surgery will also improve patient safety, by bringing in practice standards where there have been none,’ MBA Chair Dr Anne Tonkin AO, said.

Further background

Cosmetic surgery one year on

The Independent review of the regulation of medical practitioners who perform cosmetic surgery report was released on 1 September 2022. It identified 16 reforms for regulators to improve patient safety, with almost all reforms now complete.

The Cosmetic Surgery Hotline, launched on 5 September 2022, has received 428 calls including from patients concerned about their treatment, from other doctors who have had to address poor outcomes, and from consumers who are keen to make informed choices. In the same period, we have received 179 formal complaints or notifications. As a result, 14 doctors are no longer practising cosmetic surgery or have significant restrictions in place as an interim measure while investigations continue. A further 12 doctors had restrictions placed on their registration after an investigation.

These restrictions include suspension of registration, prohibition on performing cosmetic surgery, supervision requirements and formal education requirements. Our proactive advertising audits have also had an impact. In one case, a doctor’s cosmetic surgery advertising was found to have several issues such as claims of permanent results (misleading), claims to improve self-confidence and self-esteem (misleading), videos of patients talking about their experience (testimonial) and use of stock imagery rather than genuine before and after photos (unreasonable expectation). The doctor changed their advertising to address some of the issues, but after several attempts to work with them on the remaining issues failed, the Medical Board imposed conditions requiring education about the advertising guidelines and restricted the practitioner’s advertising until they completed the education.

Background – case examples

Yasmin*, a patient with a history of mental illness disclosed her history of body image issues to her doctor ahead of a series of filler injections. She also disclosed a history of 10 previous non-surgical cosmetic procedures she was unhappy with. Despite this, the doctor provided the filler injections as well as further treatments a month later. An investigation found the doctor failed to manage the patient’s mental health concerns, continued with treatment despite her body image issues and did not properly gain consent. Conditions are now on the doctor’s registration restricting practice.
Jennifer* was treated with dermal fillers by a registered nurse, despite having several known skin conditions that made the treatments inappropriate and dangerous. Following treatment, Jennifer had an adverse reaction to the treatment which required the fillers to be dissolved and steroid treatment to address the reaction. Additionally, the nurse inappropriately altered her treatment notes after a complaint was made. Following an investigation, the Board imposed conditions requiring the nurse to undertake formal education and provide a report reflecting on how they will change their practice in future.
Amy* underwent intense pulsed light treatment with a doctor to improve the appearance of skin on her neck, but instead suffered significant burns including large purple blistering. She claimed the doctor did not obtain correct consent for the treatment, did not first test the treatment on her, used an incorrect setting that burned her, and did not stop when she complained it was hurting or send her for specialist care to address the burns. After receiving the notification, the Medical Board took immediate regulatory action to protect the public while awaiting the outcome of the investigation. This required the doctor to be supervised by another doctor when performing any cosmetic procedures. Following completion of the investigation, the Medical Board continued to hold concerns about the doctor’s practice and they continue to require supervision when using intense pulsed light treatments.
Carly* suffered an infection in her cheek following a botched cosmetic thread lift procedure, that was undertaken as part of a training session for doctors and nurses. Carly’s face become so infected she required surgery to firstly remove an abscess, and then surgery to restore her appearance. The doctor who led the thread lift was cautioned for failing to obtain informed consent, organise appropriate follow-up care, or use adequate infection control techniques. Another doctor who performed a similar procedure during the same training session was similarly cautioned.

*Names have been changed to protect identity.

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Page reviewed 5/09/2023

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