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Scalpels at the ready: surgeons demand unenforceable regulation scheme be shelved

Ineffective Register Little Better than ‘State-Sponsored Marketing of Cosmetic Treatments’

London – 13 September, 2010 – Despite not being the main purveyors of cosmetic injectables such as dermal fillers and Botox, it is all too often plastic surgeons who are left to pick up the pieces when treatments go wrong. A new government-sponsored ‘Quality Assurance Mark’ for providers of these non-surgical procedures is currently live online and due to launch to the public this week, but the UK’s top surgeons are calling for the unenforceable register to be put on hold pending guidance from the British (BSI) and EU Standards Agencies (CEN). The British Association of Aesthetic Plastic Surgeons ( warns the public that the current scheme makes no distinction between practitioners who have trained for six or more years and those who simply took a weekend course. A recent poll among its members revealed that less than 4% of surgeons would even consider signing up to the scheme.

The ‘Quality Assurance Mark’, granted to those providers of injectables who sign up to the TreatmentsYouCanTrust website, was set up by the Independent Healthcare Advisory Services (IHAS) in conjunction with the Department of Health, which provided them with £200,000 of public money. The BAAPS have long held that as IHAS is, in part, funded by the clinics who have a major vested interest in this market, it is a clear conflict of interest and therefore inappropriate for them to have a role in its regulation.

According to consultant plastic surgeon and BAAPS President Nigel Mercer;

“It is evident from the information circulated by the IHAS to the profession that the scheme is being used as a marketing tool, its regulation appears rudimentary and their ‘Quality Mark’ is not recognised by the British Standards Institute or any other regulatory body.”

Many points of contention stem from the IHAS’ own press releases, which state “The Quality Assurance Mark will bring clear commercial advantage to those who display it”, and their claims that the register has already brought increased amounts of business to those who have signed up in the past few months.

Nigel Mercer says;

“No regulation scheme should be set up in the interest of bringing in business. For example, clinics already have to register with the Care Quality Commission because it is the Law and it is the job of this agency to regulate the facilities where these treatments are performed. The IHAS scheme is not enforceable and has no teeth to stop poor practice. It seems to be sold to the profession on the basis of marketing rather than patient safety.”

In response to implications that they are simply being ‘protectionist’, surgeons state that it is precisely because injectables do not make up the bulk of their practice (according to Allergan, plastic surgeons make up less than 2% of Botox sales) that they can be objective and keep patient safety as the main goal. A recent survey of BAAPS members revealed that one in four had seen patients who needed surgery to correct permanent filler complications, mainly due to unqualified practitioners administering them incorrectly.

Nigel Mercer adds;

“On several occasions, the BAAPS has written to IHAS asking questions about their scheme to clarify the situation. These questions remain unanswered: How can a one-off fee approve an entire chain of clinics and not its individual practitioners? Surely it is the practitioners who need regulating and not the company ‘brand’? How will the public be protected from the cross-selling of other procedures, including invasive surgery? Most worryingly, there seems to be no differential made between the qualifications and training of the doctor - for example BAAPS members, which include surgeons and dermatologists, must undergo a minimum of six years training and are examined in cosmetic procedures before they are eligible for membership. The unenforceable IHAS register seems to amount to State-sponsored marketing of cosmetic procedures, and that is not appropriate for any regulation scheme.”

The process of European Regulation of cosmetic procedures has started through CEN, one of the recognised EU Standards Agencies, and the Standards produced will have EU (CE Mark) and National backing through the British Standards Institute (BSI) in the United Kingdom. These standards will have patient safety at their core and will not be primarily a marketing tool. They will have 'teeth' because they cannot be ignored by National Governments.

According to Nigel Mercer;

“The BAAPS urges the new Government to wait until the EU standards are in place and to withdraw support for the IHAS scheme as it stands.”

This month sees the renewal of the BAAPS’ gritty black-and-white ad campaign depicting a life-size scalpel, to remind the public that aesthetic plastic surgery is a serious and life-changing decision.


The BAAPS (, based at the Royal College of Surgeons, is a not-for-profit organisation, established for the advancement of education and practice of Aesthetic Plastic Surgery for public benefit. Members undergo thorough background screening before they can join. Information about specific procedures and surgeons’ contact details can be found on the website, or by contacting their office at 020 7430 1840. Further materials can be posted to members of the public seeking specialised information. BAAPS is also on Twitter:   and Facebook:

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