Working in cosmetic injectables
The beauty industry has seen exponential growth in recent years, with the number of nurses working in Aesthetic/Cosmetic Nursing Practice also increasing. This field of practice holds many attractions including flexibility, financial incentives, autonomous practice, and relief from traditional nursing roles in the post pandemic context.
However, Aesthetic/Cosmetic nursing practice has challenged regulators to recognise non-traditional nursing roles and will continue to evolve in the future of healthcare. Keeping abreast of new contexts of practice and driving professional practice through collaboration with nursing regulators, institutions of education and professional associations, remain a priority to support the nursing and midwifery regulator’s primary role to protect public health and safety.
In NSW the Nursing and Midwifery Council of New South Wales (NMC) co regulates in partnership with the Health Care Complaints Commission (HCCC) and the Nursing & Midwifery Board of Australia (NMBA). In July 2016 the NMBA released the first Position Statement on Nurses and cosmetic medical procedures (Position Statement) and in June 2022 it released the fourth iteration.
The HCCC received a complaint from a client (Tom) post cosmetic procedure with (20) before and after photos attached. Tom is unhappy with the outcome and complains that Mariam is administering dermal fillers and anti-wrinkle treatment as an Enrolled Nurse (EN) and without the supervision of a Registered Nurse. The sequence of events is:
1. HCCC alerts the NMC of complaint.
2. NMC conducts a risk assessment to determine whether interim urgent action should be taken to protect public health and safety.
3. HCCC continues to investigate the complaint whilst the Council requests further information from Mariam to understand any risks.
4. Mariam provides information confirming that she:
- has been registered as an EN for less than 12 months
- immediately started working as an EN in an aesthetic company then after 6 months she opened her solo aesthetic business
- administers treatments including dermal fillers, anti-wrinkle and autologous platelet-rich plasma (PRP) treatments
- was not aware of the requirement to work under the supervision of a registered nurse
5. The Council decides urgent action is required and places temporary conditions on Mariam’s registration – the conditions require Mariam to always practise under the direct supervision of a registered nurse.
A fundamental requirement which applies to all ENs regardless of area of practice is that they must work under the supervision of an RN.
In its Position Statement: Nurses and cosmetic medical procedures, the NMBA provides vital information for registered and enrolled nurses working in or thinking about working in cosmetic medical procedures. Importantly, the NMBA has clarified that courses leading to registration as an EN do not adequately prepare ENs for the risks and complexities associated with cosmetic procedures including cosmetic injections.
ENs planning to practise in cosmetic medical procedures are required to demonstrate the following experience and education requirements prior to commencing in cosmetic nursing practice:
• practise for a minimum of one-year full-time equivalent post initial registration to consolidate the foundational skills and knowledge of an EN, plus
• two years’ full-time equivalent experience in a related area of practice (for example dermatology, general surgery) prior to practising in cosmetic medical procedures, and
• completed formal education that is relevant to the practice in cosmetic medical procedures practice.
At all times, the EN retains responsibility for their actions and remains accountable in providing delegated nursing care. Where competence has not been demonstrated and appropriate education, training and experience has not been undertaken, the EN refrains from undertaking related activities.
Complaints related to Aesthetic/Cosmetic nursing practice are highlighting new concerns which have not traditionally applied to nursing practice including issues regarding business practices, use of social media and pricing. Complainants are often business competitors or clients seeking refund, compensation or some other form of redress; however, the Council does not have the power to order a nurse to provide a refund or pay compensation.
All practitioners must keep abreast of the changing regulation across their field of practice including their own scope of practice and education responsibilities, even more so if they are working as a sole trader or business manager.
6. The HCCC will investigate the Complainants concerns using their investigative powers under the Health Care Complaints Act 1993 s13(1)
7. The HCCC and NMC will consult at the completion of this investigation as to who will continue managing the notification to ensure protection to public health and safety.
In addressing this notification, Mariam will be required to demonstrate how she meets the NMBA requirements outlined in the Position Statement. To note, there are also regulatory guidelines for Registered Nurses and Nurse Practitioners in this field of practice, please refer to the NMBA, AHPRA, ACN and Poisons and Therapeutic Goods Amendment (Cosmetic Use) Regulation 2021 website links for a comprehensive view of current available information.