Performing non-surgical cosmetic procedures

The guidelines apply to all health practitioners registered under the National Law who are performing non-surgical cosmetic procedures except medical practitioners.

Medical practitioners should refer to the Medical Board of Australia’s Guidelines for registered medical practitioners who perform cosmetic surgery and procedures.

People put their trust in registered health practitioners to provide safe and appropriate care.

The public are likely to have greater expectations of a registered health practitioner providing cosmetic procedures as cosmetic procedures are seen by the public as a type of, or similar to, healthcare in that they involve treatment of or advice about the human body. There is an expectation then that registered health practitioners using their protected titles and providing cosmetic procedures are practising to the standards, codes and guidelines set by National Boards.

Some cosmetic procedures are restricted to particular professions¹, require an authorisation only available to certain registered health practitioners² or require particular anatomical, physiological pharmacodynamics or pharmacokinetics knowledge.

Registered health practitioners wishing to undertake cosmetic procedures should be certain that they possess sufficient knowledge, skills and competence, along with any authorisation or licensing requirement for the procedure.

Even if a practitioner believes they possess adequate knowledge, skills and competence to safely perform a cosmetic procedure, the procedure may not be within the practice of their profession. The scope of a practitioner’s practice may also be limited by other guidance from their National Board³ along with legal, workplace and regulatory requirements, such as drugs and poisons legislation as in effect in each state and territory.

Non-surgical cosmetic procedures are procedures where the dominant purpose of the procedure is to achieve what the person perceives to be a more desirable appearance. Procedures that are undertaken to revise or change the appearance, colour, texture, structure or position of bodily features or bodily tissue (such as teeth) for this purpose are cosmetic procedures.

Examples of cosmetic procedures include, but are not limited to, prescription only cosmetic injectables such as botulinum toxin⁴ and dermal fillers (also known as soft tissue fillers), fat dissolving injections, thread lifts, sclerotherapy and microsclerotherapy, CO2 laser skin resurfacing, cryolipolysis (fat freezing), laser hair removal, dermabrasion, chemical peels and hair transplants.

No. It is not possible to provide an exhaustive list of non-surgical cosmetic procedures as it is the dominant purpose of the procedure that determines whether it is considered a non-surgical cosmetic procedure.

Generally, the registered health practitioner who is physically present with the person and attending to their care is the responsible practitioner for ensuring the requirements within the guidelines are met.

However, where a cosmetic procedure involves a ‘prescription only’ medicine, the registered health practitioner who is the authorised prescriber will continue to have obligations for the care of the person under the drugs and poisons legislation (or equivalent) of the jurisdiction in which they are practising, regardless of whether they perform the cosmetic procedure or not. Read more about responsibilities of both prescriber and administrator in the guidelines.

The Codes of conduct stipulate that a practitioner delegating the care of a person to another remains responsible for the overall management of the person. The Code of Conduct also outlines the responsibilities of registered health practitioners around teamwork and collaboration, including the need for registered health practitioners to be clear on who is coordinating the person’s care.

No. All practitioners are expected to possess the necessary skills, training, and competency for the scope of their practice. This is an existing requirement in the Codes of conduct for registered health practitioners.

What is appropriate training and education in order to practise safely and competently in non-surgical cosmetic procedures will vary depending on an individual practitioner and the cosmetic procedure they intend to provide. Practitioners are responsible for knowing the limits of their own scope of practice and for ensuring they are educated, trained and competent to carry out any activities they take on.

Competency is not confined to the ability to carry out the procedure. It also includes having the understanding, skills and values to consider whether the treatment is justified in the circumstances, including any risk of harm to the person, along with knowledge of the potential complications and risks associated with any procedure, and the ability to manage these risks and complications should they arise.

The guidelines provide an indication of the minimum type of education that would be considered adequate in order to perform a cosmetic procedure safely. The requirements identified are:

• appropriate training in relevant anatomy and physiology
• training on assessment of a person for suitability of the procedure
• both theoretical and hands on training in the specific procedure being offered. Training should include assessment and demonstration of competence to safely perform the procedure and care for the person, including how to manage any complications and side effects in the short and long term.

Newly graduated practitioners in some professions will have received adequate training and education to competently provide some procedures that fall within the definition of cosmetic procedures. Other practitioners are unlikely to have received sufficient training and education through their foundational qualification and would need to undertake significant training and education and experience before they could be considered safe and competent to provide cosmetic procedures.

When a Board receives a notification (complaint) about a cosmetic procedure by a registered health practitioner, it considers whether the practitioner was practising within their scope of practice having regard to the training, education and experience of the individual practitioner.

National Boards consider that it is not appropriate to prescribe Botulinum toxin and dermal fillers for anyone under 18 years of age for cosmetic purposes.

Registered health practitioners must know and comply with the relevant legislation of the jurisdiction in which they are practising in relation to restrictions on non-surgical cosmetic procedures for people under the age of 18 years.

The guidelines require practitioners to consider the appropriateness of any non-surgical cosmetic procedure for a person under the age of 18 years old. This is to protect the wellbeing of younger people seeking non-surgical cosmetic procedures.

Competence to consent is not the only consideration for a registered health practitioner in considering whether or not a non-surgical cosmetic procedure is appropriate. Practitioners may still form the opinion that it is not appropriate for the non-surgical cosmetic procedure to go ahead, having regard to the vulnerability of the person or other contraindications, regardless of their capacity to consent. In line with the Code of conduct, registered health practitioners are required to consider the balance of potential benefit and harm in all decision making.

The level of assessment undertaken should be proportionate to the individual risk of the procedure for that person. A formal psychological assessment is not required unless a practitioner, after assessing a person, considers it necessary.

The Code of Conduct requires registered health practitioners to take a patient centered approach by considering the person’s history, including relevant psychological, social, and cultural aspects.

Similarly, the guidelines require a holistic assessment of suitability based on the individual risk for each person. This includes not only an assessment for underlying psychological conditions, such as BDD, but should include an assessment of physical health, skin integrity, Fitzpatrick skin type (where relevant) or any other condition which may mean the cosmetic procedure is not appropriate for that person.

Literature and research show that psychological disorders, such as BDD, are more prevalent in the group that seeks cosmetic procedures when compared to the general population. An assessment of an individual seeking non-surgical cosmetic procedures should therefore consider whether an underlying psychological disorder, including BDD, makes the person an unsuitable candidate for the cosmetic procedure.

No. All registered health practitioners are expected to have and maintain an adequate knowledge base for their scope of practice. Given that psychological disorders, such as BDD, are more prevalent in the group seeking non-surgical cosmetic procedures, all practitioners working in the non-surgical cosmetic procedures industry should ensure they are adequately trained and educated to identify any condition, including underlying psychological disorders, that may indicate a person is not a suitable candidate for the cosmetic procedure.

If you have concerns about the way a practitioner is practising you can raise a concern through the Ahpra website.