Regulation of non-surgical cosmetic procedures – equality impact assessment questionnaire

Share your views on how proposals to regulate non-surgical cosmetic procedures might impact you.

The Quality and Safety Unit in the Scottish Government’s Directorate of the Chief Operating Officer of the NHS are preparing legislation to regulate non-surgical cosmetic procedures (like Botox^® injections, chemical peels, dermal fillers and laser treatments). They would like to gather the views around how their proposals might impact upon you. This will inform an Equalities Impact Assessment on the subject.

Background

There are a variety of non-surgical cosmetic procedures (NSCPs), with different methodologies and different degrees of invasiveness and risk. NSCPs include any methods that pierce or penetrate the skin, whether through needles and the use of injectables or through treatments that use heat, cold or light and lasers. The definition excludes those procedures which are considered surgical, and thus restricted to appropriate professionals. It also excludes non-penetrating cosmetic procedures and massages; and procedures undertaken for non-cosmetic (ie medical) purposes. NSCPs may be undertaken by a medical practitioner in a clinic or by a non-healthcare professional in a salon or similar context. Some practitioners may operate peripatetically, or out of their own homes.

Non-healthcare professionals are not regulated as medical practitioners are, and this lack of oversight means that it is difficult to know where or by whom services are being provided and how procedures are being performed, and to take the necessary actions when patients are being harmed.

The current policy aim is to introduce schemes whereby lower risk NSCPs can only be carried out in licensed premises by suitably qualified licensed individuals, and medium to high, higher intervention, NSCPs can only be carried out by or under the supervision of certain healthcare professionals and therefore in settings regulated by Healthcare Improvement Scotland (HIS). This will lead to improvements in standards of training, hygiene and safety, and allow for an enforcement regime for those premises and individuals.

They are also looking at introducing age restrictions for NSCPs, aligned to the current age restrictions for tattooing and piercing.

What we need from you

To progress this work they are legally required to complete impact assessments to understand how the proposals may affect various groups in Scotland such as: children and young people, island communities, people from lower socio-economic backgrounds and those with protected characteristics as defined by the 2010 Equality Act.

In order to do this they would like your input to ensure that no one is unfairly disadvantaged or discriminated against by this proposed policy. They have designed a short questionnaire (attached below). They would appreciate if all responses could be returned to their inbox at cosmetics.consultation@gov.scot by no later than 1 July 2025.

If you have any questions regarding this please feel free to contact: cosmetics.consultation@gov.scot.

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