Citizen Participation and Public Petitions Committee 05 March 2025
That brings us to the last of our new petitions this morning. PE2137, on fair regulation for non-medical aesthetic injectors, which has been lodged by Jordan Morrison of Mr Skulpt Aesthetics Ltd, calls on the Scottish Parliament to urge the Scottish Government to introduce an aesthetics licensing scheme to ensure that non-medical practitioners meet training and safety standards.
The petition argues that a complete ban on aesthetic injectors risks driving treatments underground, where unregulated and untrained individuals could operate without oversight, which would significantly increase the risks to public safety. The petitioner states that, by contrast, regulation would mandate accredited training, on-going education and adherence to strict safety protocols, thereby ensuring that injectors had the necessary knowledge to perform procedures responsibly.
The SPICe briefing explains that, currently, the only clinics that are regulated are those where qualified registered health professionals work; they are registered and inspected by Healthcare Improvement Scotland. A review of the regulation of cosmetic interventions recognised that, because many procedures are not fully covered by existing regulatory frameworks, anyone can purchase and administer products, despite the potential for significant harm.
The Scottish Government consulted on the regulation of non-surgical procedures that pierce or penetrate the skin in 2020, and the analysis was published in 2022, with the Scottish Government indicating that it might introduce a licensing scheme for all practitioners who carry out such work. However, that did not happen.
In its response to the petition, the Scottish Government states that its most recent consultation, which closed on 14 February, builds on the 2020 consultation by putting forward more detailed proposals for what further regulation could look like. It also states that the consultation does not propose a ban on non-healthcare professional practitioners performing injections of Botox or dermal fillers; instead, it is proposed that certain procedures should be undertaken in a premises regulated by Healthcare Improvement Scotland, and that they should be undertaken by a trained practitioner working under the supervision of an appropriate healthcare professional, who would be available to prescribe any prescription-only medicines that might be required in the procedure or to support the management of any complications.
The Government will confirm any plans for legislation that might be required once the consultation responses have been analysed.
We have all been made aware, through the media, of one or two quite distressing examples of this issue manifesting itself. Do colleagues have any suggestions as to how we might proceed?