Aesthetics Health & Safety Copy
Aesthetics Health & Safety
Advertisements on Prescription-Only-Medication (POM) Treatment
New enforceable guidelines for advertising Prescription-Only-Medication such as Botulinum Toxin or Vitamin Injections such as B12, C & D came into effect on the 31st of January 2020. This is regulated by the Committee of Advertising Practice (CAP), which will use specialist new monitoring technology to discover non-compliant ads and act. One such outcome may be the reporting of specific ads or posts on social media platforms like Instagram.
The Advertising Standards Authority (ASA) was established in 1963 as an industry watchdog to monitor and adjudicate any breaches of the British Code of Advertising Practice (CAP Code) with the primary objective of protecting the public from inaccurate, inappropriate, or misleading adverts, whether online, in print or via broadcast.
Any promotion of a POM to the public is a breach of the CAP Code and an offense under the Human Medicines Regulations 2012.
Code 12.12 of the CAP states that “Prescription-only medicines or prescription-only medical treatments may not be advertised to the public.”
Administration of Prescribed Products
The Medicines and Healthcare products Regulatory Agency (MHRA) states that any person can administer certain prescribed products, i.e., Botulism Toxin, in accordance with the guidance of an appropriate practitioner. This means that according to the MHRA, Non-prescribers and non-medics can administer procedures using prescribed products following instruction from either a doctor, dentist, or appropriately qualified independent prescriber.
Beyond the administration of these products, they are prescribed drugs, and therefore there are strict guidelines as to who can prescribe the medication. Prescriptions should only be issued after adequately assessing the client and giving client-specific instructions (ideally written). Non-medics or nurses are not allowed to prescribe these products for use, but if they have been given a prescription with specific instructions by the prescriber for the client, then the non-medic or nurse may administer the treatment. Prescriptions should not be done remotely as most products used are being used ‘off-label’ for non-essential purposes. The client should be seen in person by the prescriber.
Remote prescribing of Botulinum Toxin is now banned under the NMC, GMC, and GDC and absolutely should not be considered as an alternative to a face-to-face consultation.
In general, products required cannot be supplied in advance but on a per-client basis. However, the MHRA does state that doctors can supply advance stocks to ‘nurses and others who are employed within the same legal entity. Even though the items can be supplied in advance stocks under these circumstances, client-specific advice must still be given to the person administering the procedure.
It is important to note that the manufacturers of many products used in aesthetic procedures state that the treatments should be administered by medical practitioners. Non-medics should consider these guidelines carefully and ensure they have the correct and appropriate training and professional indemnity insurance in place.
Medications are intended to be for the person in which they are prescribed too and should be administered as such. Full records should be kept for up to 6 years, including the prescriptions and batch numbers and full details of the treatments and outcomes.