Meeting of the Parliament 17 March 2026
As far as the part of the bill on certification of death is concerned, we agree with it.
I begin with a declaration of my interest as a registered general practitioner. I am registered with the General Medical Council.
At its core, the legislation is about one fundamental principle: patient safety. At the moment, in parts of the non-surgical cosmetics sector, that safety is far too inconsistent. To put it bluntly, in some areas, the situation resembles the wild west. Yes, there are genuinely good businesses, but there are also shocking ones that perform botched surgeries. That would be unacceptable in absolutely any other area of healthcare, yet, for far too long, that is, in effect, what we have allowed to develop. The procedures that we are discussing are often presented as simple, routine beauty treatments, but, in reality, they involve needles, injections, prescription-only medications such as botulinum toxin and substances being injected under the skin. When something goes wrong, the consequences are not trivial; they include permanent scarring, tissue damage, severe infection, psychological trauma and emergency hospital treatment—and when complications occur, it is the national health service, which is under immense pressure, that ends up treating the patient.
It is worth remembering that botulinum toxin is derived from one of the most powerful biological toxins known to science. Used correctly, in the right hands and the right clinical setting, it can be administered safely. The key words there are “correctly” and “safely”—that means trained practitioners, appropriate clinical environments and proper safeguards. However, at present, some procedures are carried out in in settings that could never be described as, or considered, acceptable in any other part of healthcare. We hear about fizz and filler parties, at which you can get your Botox and your fillers while drinking champagne; treatments delivered from spare rooms in houses; and procedures performed in hotel rooms or pop-up settings with little clinical oversight. No one in this chamber thinks that it would be acceptable to receive antibiotics or other medicines from someone who was not properly regulated and insured and working in a safe clinical environment, so why do we accept that injectable cosmetic treatments are treated so differently?
I want to be clear that many practitioners who work in the sector take their responsibilities extremely seriously. They operate from clean, sterile environments, follow proper consent procedures and understand how to recognise complications. I have every sympathy with those practitioners. In fact, many of them support stronger regulation, because they are frustrated at being undercut by individuals who complete a very short training course and immediately begin carrying out invasive procedures. Proper regulation should be seen not as an attack on the sector but, rather, as protecting the reputation of responsible businesses and creating a level playing field. Yes, regulation might bring additional costs, but the reality is that good practitioners are already meeting those high standards and regulation is aimed at raising the floor. It ensures that poor practice must not and cannot continue unchecked. Above all, this is about protecting patients.
We also know that there are cases in which procedures go beyond cosmetic injections. There have been reports of practitioners removing moles or skin lesions without ensuring that samples of them have been properly examined. That raises serious concerns about misdiagnosis, including of skin cancer. Even as a GP who sees skin lesions all the time, I refer any lesion that I am unsure about to dermatology. When we remove lesions, we send them to histology to ensure that our assessment is correct and to ensure that a cancer has not been missed. There is no safety mechanism in the bill to address that risk. Again, this is not a minor issue; it is a matter of potentially life-saving clinical practice.
The truth is that we are a decade behind where we should be in regulating the sector. The popularity of non-surgical cosmetic procedures has grown rapidly, but the regulatory framework has not kept pace. Therefore, the bill is a very important and necessary step. It recognises that, if a procedure pierces the skin, involves injectable substances or uses prescription-only medication, the standards governing that practice must reflect the clinical risk that is involved.
However, what is aimed for through the legislation will be achieved only if it is properly implemented. If we are serious about regulation—and I am—Health Improvement Scotland must have the necessary resources to enforce it effectively. Without that capacity, even if the legislation is drafted to the highest level, HIS will struggle to deliver what the patient requires and the protection that we intend.
The bill is not about restricting innovation or closing down responsible businesses; it is about bringing order to what has often resembled the wild west.