Legal Issues
Can Beauty Therapists Inject Botox in The UK?
Disclaimer: The information on this site does not constitute legal advice. Any beauty therapist considering practicing in the field of injectable aesthetics should make an independent assessment of his or her own legal position.
It should be noted that the injection of Botox by beauty therapists in the UK and worldwide is a contentious issue. There are concrete reasons for this, first and foremost being public safety. Besides this issue, there are many lobby groups which have financial interests to prevent beauty therapists from practicing in the field of injectable aesthetics.
Today, doctors, dentists, nurses and midwives undertake Botox training and practice in the field. These days it is taken for granted that these professions practice injectable aesthetics, however in the past there was significant lobbying against this. Initially plastic surgeons spoke out against other medical professionals practicing injectable aesthetics, and subsequently medical lobby groups tried to prevent nurses and midwives from practicing cosmetic medicine. These days the groups that previously fought for the right to practice cosmetic medicine try to prevent beauty therapists from practicing in the same field and eating into their market share.
Regarding the question whether beauty therapists can legally administer Botox, we should look at the stance of the Department of Health and their executive arm, the Medicines and Healthcare products Regulatory Agency (MHRA).
The MHRA has put out a FAQ regarding the administration of Botox and similar substances for cosmetic purposes. To summarise the contents of the guide, the MHRA states that any person can administer Botox in accordance with the guidance of an appropriate practitioner. This means that according to the MHRA, beauty therapists can administer Botox following instruction from a doctors, dentist or appropriately qualified independent prescriber.
However beyond the administration, Botox is a prescription drug and therefore there are strict guidelines to who can prescribe the medication. Botox can only be prescribed by a medical practitioner or an independent prescriber. The prescriber should prescribe Botox only after adequately assessing the patient and giving patient-specific instruction (preferably written). Beauty therapists are not allowed to prescribe Botox, but a client who has been given a prescription with specific instructions by the prescriber can have the substance administered by a beauty therapist. While it is not the consideration of the beauty therapists, remote prescription by a prescriber is generally not advised since Botox is used off-label and for non-essential purposes. Ideally the patient should be seen in person by the prescriber.
In general, Botox cannot be supplied in advance but only on a per patient 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 substance may be supplied in advance stocks in this case, patient-specific advice must still be given to the therapist administering the treatment. There is no legal way for beauty therapists to obtain wholesale supplies of Botox.
It should be noted that the manufacturers of Botox and dermal fillers in state that the treatments should be administered by medical practitioners. The Botox leaflet clearly states that it should be administered by “physicians with appropriate qualifications” and the Restylane leaflet states that “only medically qualified healthcare professionals should administer Restylane injections e.g. plastic surgeons, dermatologists, doctors and registered nurses.”
Beauty therapists should consider these guidelines carefully and seek legal advice, if appropriate, prior to undertaking Botox training. In any case, beauty therapists administering Botox have legal responsibility for the outcomes of the treatment. Any beauty therapist operating in this area should have appropriate professional indemnity insurance.