Women and Equalities Committee
Oral evidence: Cosmetic procedures: follow-up, HC 307
Wednesday 9 September 2026
Ordered by the House of Commons to be published on 9 September 2026.
Members present: Christine Jardine (Interim Chair); Alex Brewer; Rosie Duffield; Kim Leadbeater; Kevin McKenna; Richard Quigley; Rachel Taylor; Nadia Whittome.
Questions 1 - 35
Witnesses
I: Ashton Collins, Director, Save Face; Nora Nugent, Cosmetic Surgeon and President, British Association of Aesthetic Plastic Surgeons.
Witnesses: Ashton Collins and Nora Nugent.
Q1 Chair: Welcome to the Women and Equalities Committee and our inquiry on cosmetic procedures. My name is Christine Jardine and I am the MP for Edinburgh West. We have two witnesses today, Ashton Collins and Nora Nugent. Just before we get started I wonder if you would mind giving us a brief introduction. Ashton, if we could start with you.
Ashton Collins: I am a director of an organisation called Save Face, which is a Professional Standards Authority-accredited register for healthcare professionals that provide treatments such as fillers and Botox. We take each practitioner and their clinic through a 116-point assessment process to verify that they are safe and appropriate to provide these treatments.
Nora Nugent: I am a consultant plastic surgeon based in Tunbridge Wells and am the current president of BAAPS, the British Association of Aesthetic Plastic Surgeons. I have a reconstructive and aesthetic background but am currently in full-time private practice focusing on aesthetic surgery.
Q2 Kevin McKenna: Ashton, I will start with you. Since you last gave evidence to this Committee the Government announced their intention to launch a further consultation on the restriction of these high-risk procedures. That consultation now seems to be delayed. Are consumers any safer today than they were a year ago in the cosmetic procedures sector?
Ashton Collins: Sadly not. What we have seen as a result of these delays has been further unintended consequences. The last time I came I spoke about the dangers of liquid BBLs being carried out on the high street by unqualified practitioners. Unfortunately those risks have now escalated to a point I do not think anybody could have imagined. You have lay people performing plastic surgery procedures involving scalpels and vast quantities of anaesthetic in people’s living rooms and dingy salons on the high street. They are performing facelifts, blepharoplasties, intimate procedures and liposuction, all without consequence.
Q3 Kevin McKenna: Nora, does that align with your understanding?
Nora Nugent: Sadly it does; I would have to agree with Ashton. We had this conversation about the potential consequences at the inquiry. Over the last year we have had it brought to our attention several times that plastic surgery procedures are being performed—as Ashton says—in private homes and beauty salons with the practitioner of unknown origin in terms of what their qualifications are and being able to track them down. There is one particular person, but there have been a few copycat instances as well. Sadly we are no further forward and probably a little backwards.
Q4 Kevin McKenna: Is there any indication that even just by announcing this consultation some practitioners may have improved their practices and bucked up their ideas a bit? Has it changed any discourse in a positive way for anyone?
Nora Nugent: It has helped raise awareness of the issue. I know we have been talking about it for a long time, but this inquiry reached the media and all the professional groups and came to the awareness of people. Unfortunately the people who are not bothered about regulation are also not bothered by the pace of action and anticipate a slow pace of action. It has raised awareness but I do not think it has been enough to prevent what is going on. There are very few who have actually shut their doors.
Q5 Kevin McKenna: Ashton, have the numbers and types of complaints that you get at Save Face changed at all?
Ashton Collins: Fortunately in some ways they have. Our campaign work on Alice’s Law—to prevent liquid BBLs being carried out on the high street by lay people, essentially—has seen a huge success. At the height of its popularity from late 2023 and through 2025 we were averaging about six to nine complaints every week about these procedures. That has now fallen to about six complaints per month, which is a dramatic decrease. As I said, unfortunately these practitioners are now pushing the boundaries even further and are now wielding scalpels. The risk profile in terms of these treatments is escalating and that needs to be nipped in the bud as a priority.
Q6 Kevin McKenna: From your point of view, with this gap now widening between Government announcements and not even the intervention but the consultation and the implementation of any changes, what impact do you feel that has had on public confidence, particularly in the regulatory system as a whole?
Ashton Collins: It is very damaging to public confidence. People deserve to be protected from these rogue operators, and unfortunately from themselves as well. Because of social media and things, the trivialisation of these treatments has become significant. People do not always appreciate that these are high-risk medical interventions and when they see these cheap deals being advertised on places such as TikTok they think that they are going to be in safe hands. It is only when they arrive that they realise it is a home, but by that point they have already paid their money and committed to having the treatment so they do not back out. People do not appreciate the risks that they are getting into and the Government are responsible in part for not taking action sooner.
Q7 Kevin McKenna: Nora, obviously as a surgeon you are fully registered and compliant and have many regulatory responsibilities and oversight. From your point of view as a professional, what do you feel the impact of this is on the public perception of the regulatory system?
Nora Nugent: It is very damaging, because it seems like the regulatory system does not matter or only applies to some people but not others and that if you do not comply there is no consequence, which reduces confidence overall. You are right; I am on the GMC register, I have to have a certain amount of medical indemnity, I have to go through appraisal and revalidation and I have gone through the Royal College of Surgeons Intercollegiate Cosmetic Surgery Certification Scheme.
That does not stop others who have done none of that from putting themselves forward as cosmetic surgeons. The general public find it very difficult to distinguish between the different layers of who is actually a plastic surgeon and who is just calling themselves a cosmetic surgeon but may not even be a surgeon, never mind a cosmetic surgeon. It undermines public confidence and confuses people.
Kevin McKenna: I am no longer a practising nurse and have come off that register but I completely back up what you are saying.
Q8 Richard Quigley: It may seem an overly simplistic question, but what do you think is the motivation for people who are performing these procedures? Is it just as simple as money?
Ashton Collins: Yes, in the vast majority of cases, and because they can. I am very mindful that as much as public awareness helps people avoid falling into unsafe hands, it has unintended consequences. It has reached people who are unscrupulous and now are aware that it is not illegal for you to pick up a scalpel and operate on somebody or perform a liquid BBL. When you find out how much money there is to be made and how many procedures you can do in a week or a month, that is very appealing to these unscrupulous people.
Q9 Nadia Whittome: Ashton, how prevalent are serious complications arising as a result of liquid BBLs or other high-risk non-surgical procedures?
Ashton Collins: Extremely prevalent. To date we have helped over 1,200 women who have had either liquid BBL or liquid breast augmentation complications. Over 50% of those women have had sepsis and been hospitalised. A further 40% have needed extensive corrective surgery and ongoing district nurse care. I cannot stress strongly enough how much of an impact that has had on their lives. More recently we have seen women who have had blepharoplasties carried out in people’s living rooms and cannot close their eyes. They have to tape their eyes closed to go to sleep. That is a permanent complication that they will be left with for life.
Nadia Whittome: That is horrific.
Ashton Collins: It is terrible. It is like something out of a horror film.
Q10 Nadia Whittome: Nora, the same question to you.
Nora Nugent: Ashton has summarised the position. We hear about high-profile cases such as the recent liquid BBL death and so on, but there are numerous others who are going around with life-changing complications that have needed surgical treatment and months of dressings and have had months taken out of their lives. It impacts every aspect, not just their appearance; they cannot get back to work. We have numerous others going around with just poorly done treatments. It really is so prevalent that if you walk around any town you will find people advertising outside ASA guidelines. In beauty salons and hairdressers you will find things way outside that scope being advertised. These things are real medical procedures with medical complications. It is just an ongoing saga.
Q11 Nadia Whittome: Ashton, you have already spoken about the unsuitable settings in which these procedures are continuing to be carried out such as people’s living rooms and the high street. Is there anything that you wanted to add to that?
Ashton Collins: These treatments are being proliferated by social media and advertised extensively on there. The way in which these people operate is almost like a criminal underground: you pay them the money in advance and they will not disclose the location of the treatment setting until the day of the treatment. You are then met at your car by somebody who then escorts you to a property; they do not really want you to see where this property is. You are led with blinkers on up to a bedroom.
It is not just the settings; it is the way in which these treatments are being carried out and the clandestine, almost criminal way that they are being presented to patients. When confronted with that type of thing as a patient—people describe this—they feel terrified. They feel like they are in the witness protection programme. These people are also very aggressive. If you try to raise a concern after something has gone wrong or you are very unhappy with the outcome they threaten people with physical violence. We therefore have a lot of people who are terrified to speak out about their experiences.
Q12 Nadia Whittome: Does the same apply before the procedure in that it is not just that people are worried about losing the money that they have already paid but they actually feel too scared not to go ahead with the procedure?
Ashton Collins: Yes. Unfortunately they describe to me feeling like there were lots of red flags and they wanted to back out, but actually the pressure that they are put under while they are there is immense. They go, “Oh, no, you’ll be fine,” and, “Oh, she’s done this amount of treatments,” and they are quickly shown loads of before-and-after pictures on an iPad. They are rushed into sitting down and being prepared for these treatments and have very little opportunity to back out once they are there.
Nora Nugent: They describe this sinking feeling as they look around the room and see—even from a layperson’s point of view—the things that are not as they should be. They are in too far at that point to back out; they have already committed. For example they might see stains on a carpet or someone in normal clothes with a pair of unsterile gloves doing a procedure. They describe these kinds of scenarios and they know it is wrong. It sounds crazy but they are in so far at that point that it is actually very difficult for them to back out.
Q13 Nadia Whittome: Ashton, you spoke a bit about the unintended consequences of more public attention and media reporting in that there is now awareness that you can make a lot of money out of this without being regulated or facing any consequences. Have you seen any other changes in attitudes—either of practitioners or consumers—as a result of that increased public attention?
Ashton Collins: Yes. As I said our campaign work on the liquid BBLs—particular thanks to ITV News that covered that topic extensively—has seen a huge increase in the amount of awareness there is around liquid BBLs. Previously there was nothing available outside what people were seeing on social media. The people advertising these treatments were promoting them as being risk-free beauty treatments that were cheaper and safer alternatives to the traditional fat transfer BBL, which was obviously completely untrue. We saw a massive amount of complications. Those reports have reduced, but as I said other reports have increased significantly.
Q14 Nadia Whittome: Nora, what is your view on the Government’s proposal for a further consultation on banning these high-harm practices?
Nora Nugent: I have to be very frank: we have already had the consultation; we know the issues we have, and it will delay the much-needed regulation further by going through another consultation process. If there were to be another consultation it should zone in on the specifics of proposed legislation rather than another general consultation. We have already been through that and know the issues.
Q15 Nadia Whittome: What is your view on that, Ashton?
Ashton Collins: I agree. To my mind there is no ambiguity or contentiousness around whether somebody who is not a qualified, regulated specialist plastic surgeon should be able to pick up a scalpel and operate on somebody or perform a high-risk liquid BBL. The only people who would disagree with any sort of ban on these are the unscrupulous people who are currently capitalising on people’s insecurities and making a massive amount of money at the hands of unsuspecting members of the public.
Q16 Nadia Whittome: I suspect I know what your answer will be but if there were a further consultation, would you support a temporary ban on these practices during that consultation?
Ashton Collins: Without doubt.
Nora Nugent: I would, with the caveat that Ashton made the very correct point that there are people who are qualified to do these procedures, as in plastic surgeons. There has to be a consequence of not being qualified to do something.
I would like to make another point as this is the Women and Equalities Committee. It is mostly women who are affected by this, as the vast majority of these treatments are undertaken on women. It is women who are ultimately the ones paying the price for this lack of regulation.
Q17 Chair: Ashton, in the light of recent incidents including the botulism outbreak in 2025, do you think there should be a centralised record of non-surgical cosmetic procedures including details of the products?
Ashton Collins: Yes. However for us to get to that point would be a huge undertaking. If we look at how fragmented this industry sector is and how many different professional backgrounds operate within this space—you have on one hand the regulated and on the other hand the unregulated—creating a central data repository that houses all those things would be a mammoth task. What would be more beneficial in the short term is if the regulators took these complaints more seriously and actually policed and enforced the regulations that exist, particularly around Botox.
Remote prescribing is ubiquitous. You could go on social media this afternoon and find hundreds—if not thousands—of practitioners offering same-day Botox. They are not healthcare professionals and you would never see or speak to a prescriber; they are working with a dodgy prescriber that is giving them the products without ever seeing or speaking to the patients that they are responsible for. More worryingly they are buying illegal imported products that are not licensed for use in the UK from places such as China and Korea. We have seen a huge amount of botulism and other scary complications associated with those.
Q18 Chair: Nora, is there anything you want to add to that?
Nora Nugent: Yes. In addition to what Ashton has said, I would like to make two further points. Regulated clinics keep records of every product used, the lot numbers, the expiry dates, what was used on which patient, how much was used, and where and how it was put. There are two first steps: No. 1 is to regulate how it has been done, and then you will have proper records because regulated clinics keep records. No. 2 is ensuring that every patient gets a non-surgical passport, which can be a little book or a card where the practitioner writes in exactly what they have done. If that patient goes anywhere else—moves house or something—they then have a record of what they had. Those are two steps that could be done ahead of a central data repository, which obviously would be the ideal.
Q19 Chair: I wonder if we could just clear something up. Nora, if there is a ban on certain procedures being carried out by unqualified people, do you think a ban should still allow appropriately qualified surgeons to undertake procedures such as Brazilian butt lifts in exceptional circumstances? If so what might those circumstances be?
Nora Nugent: My simple answer is yes, but you would have to define who the appropriate person is and provide an overview of the circumstances. You will not be able to establish every exceptional case but there are examples, as I say, after trauma asymmetries. I am going to give a couple of examples, and they do not necessarily need dermal fillers as the only treatment. For example, with the buttock, after trauma or other medical conditions you sometimes have uneven contours, which is not just appearance-related; it can affect comfort when sitting and pressure areas if there is not enough padding over the area.
I want to be clear that fillers are not the only way to treat this, but there are some circumstances where buttock augmentation can have a reconstructive purpose completely unrelated to appearance. A catch-all ban does not allow for that. However, the vast majority are appearance-related procedures.
Q20 Rosie Duffield: We are going to move on to cosmetic tourism. First, I just want to say, Ashton, the work you are doing is amazing, because you are always on telly and you work your bits off to raise awareness of this; Olivia Attwood’s programme was just really informative.
To start with I just want to ask Nora in what way—if any—has the cosmetic tourism landscape changed since our Committee completed its inquiry? I am not suggesting that we have changed things, but in terms of time do you think that the trend is slowing down a bit?
Nora Nugent: The trend is slowing down a bit, but as Ashton was saying earlier, for non-surgical issues, this trend is price-driven and everything healthcare-related in the UK is at a significantly higher price point than in the countries that people are travelling to for cosmetic procedures. Price is not the only driving force but it is the predominant driving force behind it. As long as there is a price difference this will continue. We have taken some steps forward, and the rate of complications is slowing a little.
Q21 Rosie Duffield: Ashton, do you think that is another unintended consequence of all your work, that people might just go to Turkey or somewhere where it is not as regulated?
Ashton Collins: That is a possibility. As Nora said, the main driver in people going abroad for surgery is the fact that it is significantly cheaper and it is advertised in a very trivial way whereby you have this procedure done, you get this lovely holiday to recuperate and then you come back looking fantastic. The way these things are being sold is very irresponsible and misleading. As we know there is no aftercare or follow-up when they return to the UK.
Q22 Rosie Duffield: Which procedures that happen abroad are causing the most concern to you both?
Nora Nugent: For us, body contouring procedures are the ones showing up with the highest complication rates, particularly abdominoplasty or tummy tuck surgery. We have kept a database asking members to report complications that they have seen from surgery overseas. It is by no means complete data but is one of the most complete data sets that we have available.
Abdominoplasty is a strong contender for the riskiest procedure on that front. It is partly the nature of the surgery and partly adding in travel risks such as clotting and not being able to look after drains, fluid collections or wound care properly. The wound infections and healing problems are the number one problem, and abdominoplasty is the number one procedure that we are seeing.
Ashton Collins: It is particularly around these multiple procedures such as the mummy makeovers; abdominoplasty is part of that particular procedure where people are having so many different things at once. You are bound to get some sort of issue when you are having so many things done.
Q23 Rosie Duffield: What proportion of these complications that you see might have been avoided through better information and aftercare?
Nora Nugent: It is difficult to give you an exact percentage but we have had some examples of very poor patient selection, with patients with multiple medical or mobility problems then undergoing a six-hour surgery. That is always going to be extremely high risk. Some patients have been refused surgery in the UK for those reasons but have obviously sought it elsewhere. With more education for that group it is definitely preventable.
The other group we have seen is actually younger patients who may not have the same type of problem but have been talked into procedures before they needed them, in terms of facial procedures. We had one particular patient who was talked into a facelift and eyelid surgery in her late 20s, which is hard to justify for anyone no matter what the medical background is. There are some examples of very poor patient selection that are so preventable with education. There are other examples of combinations of procedures that are just not compatible with a safe recovery, a flight and lack of follow-up. Some complications are due to no follow-up and some are actual medical issues.
Q24 Rosie Duffield: This is mostly to Nora. Both this Committee and the BAAPS, which you preside over, have raised concerns about the burden on the NHS of the corrective surgery following erroneous procedures that we have heard you talk about. Are you satisfied that the NHS is capturing that data needed to understand the extent of the problem?
Nora Nugent: No. Let me be clear about what the problem is: the way the NHS looks at its activity is by codes, and the codes are procedure related. For example, if someone comes back with an abdominoplasty with an infected wound that needs three rounds of surgery to clean it up and eventually put a skin graft, they will all be coded as wound debridement and skin graft and that will pick it up. It does not distinguish that person’s procedure from someone else having an infection and needing the same procedure.
We have suggested a separate code that could be applied when the surgery has taken place overseas to capture that activity. Right now we do not have a full view of this activity. We have snapshots of it from individual hospitals, estimates and the database that I mentioned earlier where we got our members to report cases to us but there is no overriding central data collection. Our suggestion was a code that captured surgery performed overseas to lie on top of the actual procedure code. The procedure code does not tell you where the problem originated.
Q25 Rosie Duffield: Ashton, we talked about this one time when you were on the panel before, actually. Should reporting of those complications be mandatory in your opinion?
Ashton Collins: Yes. Just picking up on what Nora said, it is frustrating because we know the vast majority of these liquid BBL complications were in some way interacting with the NHS services, whether that be overnight stays, hospital intervention or whatever that might look like. Unfortunately, as Nora said, it is impossible to obtain just how much that is costing the NHS because those codes either do not exist or they are underutilised and there is no awareness among the staff that they even exist.
Q26 Richard Quigley: To Nora, but Ashton, please feel free to comment, you have made it very clear—thank you for doing so—that cosmetic surgery can still be undertaken by doctors without a specialist surgical qualification. It is 10 years since the Keogh review identified this as a concern. Why do you think this issue remains unresolved? What do you think we have not done right?
Nora Nugent: There are two issues. Obviously it is not the only issue in the country at any one time, and sometimes the more acute issue will overshoot. The other problem is that the horse has bolted to some extent. It is always easier to stop something than to stop people who are already doing it and claw back where it should never have been allowed in the first place. Essentially we have allowed the status quo and more and more people to just continue. I am talking about doctors as well as non-surgical practitioners. We have allowed people to start up and continue doing procedures they are not qualified to undertake. It is harder to claw back than it would have been to have stopped it from happening in the first place. Let us just say we have not kept up with the progress of the industry sector.
Q27 Richard Quigley: To summarise it in my own mind, is it that we have just not tried hard enough, effectively?
Nora Nugent: Yes. It takes too long and there is always a vague promise to do something and an acknowledgement that something needs to be done, but nothing actually done.
Richard Quigley: We are constantly chasing the horse after it has bolted, as you put it.
Ashton Collins: I agree completely with that. One of the biggest frustrations for us is that these complaints and complainants are not taken as seriously as they ought to be by the regulators responsible for policing current regulations, as I said with remote prescribing and illegal imports of Botox. I have supported many women who have undergone these high-risk procedures and had devastating consequences, such as Sasha Dean who accompanied me last time and spoke of her harrowing experience. Despite being given a 5% chance of living when she arrived at the hospital with septic shock—there were lots of breaches in regulation in her treatment that was carried out by that unregulated practitioner—we cannot get Thames Valley Police to take this matter seriously. There is an air of misogyny around these treatments and very much a sense that the victim is at fault, which is completely unacceptable. Had Sasha sustained those injuries in any other context at the hands of somebody else, that person would be investigated at the very least, and they are refusing to even do that.
Nora Nugent: I would like to add an important point to what Ashton has said. I agree with her, but the other problem is that if it is a doctor, nurse, pharmacist or someone regulated in a CQC-regulated premises, there is a mechanism for some degree of regulation and consequence. When someone is not registered or in a regulated environment, it falls between stools. The CQC says it is not its remit because it is not a CQC-regulated premises. The police often say it is not their remit. On many occasions we have resorted to environmental health as being the body most able to act. It is really a medical issue, not environmental health, but for the most part environmental health has been the most proactive in helping us on this side of things.
Q28 Richard Quigley: We have effectively created the perfect market for unregulated cosmetic surgery because no one wants to take responsibility for it. Is there anything that the General Medical Council can do to help curb it through licensing requirements? It may be an unfair question to ask you to solve all the problems of the world, but I have a little worry that we have created the supply chain for this industry and if we regulate it, we just force it underground. Do you have any thoughts on what we do to stop it from being forced underground and actually just stop it in its tracks?
Nora Nugent: From a GMC perspective it cannot do anything significant without legislation. Two things would help. One would be proper use of titles and not allowing regulated professionals under the GMC to call themselves miscellaneous names such as “cosmetic surgeon”. You have to stick to your regulated title, and that would clear up some misunderstanding from the general public’s perspective, and then there is the consequence.
The second would be if there were legislation behind people who act outside their scope of training and practice—for example if they were a completely different specialty or not a specialised doctor—then you could have a consequence from a licensing perspective. Without legislation to back it, it is going to be very difficult for the GMC to do anything. The latest GMC consultation has suggested removing the specialist register altogether and coming out with something called enhancements to identify a specialist going forward; none of us is entirely clear what that will mean. It certainly will not help the current situation.
Ashton Collins: I agree completely with what Nora has just said. To your point around whether there will be an underground operation, probably; there will always be people who operate under the radar. The important thing would be that if legislation were in place people would have the tools and resources to identify what is and is not illegal. People who are then named by these people who may have unknowingly fallen into unsafe hands will have a means to access justice for what they have been through. At the moment there is no justice available to these people.
Nora Nugent: It is currently not illegal for someone non-medical to inject dermal filler, so it is very hard to get a comeback when you do not have the legislation to back it. While you would probably get an underground industry, at least there would be a consequence as opposed to now when there is actually no legal standard to hold them to.
Richard Quigley: That is an interesting point that will probably shock a lot of people: it is not illegal to perform it.
Q29 Kim Leadbeater: It is lovely to meet you both. I do not think I was here at the last session so this is a whole new world for me and not necessarily in a good way. Thinking about social media and advertising, Ashton said something about irresponsible marketing and advertising. Do you think that social media platforms are doing enough to prevent the promotion of these high-risk cosmetic procedures to under 18s in particular?
Ashton Collins: No. Social media companies are wholly to blame really for why these treatments are so popular. There are so many unscrupulous providers operating out there, especially for younger people whereby social media has become a research tool for these treatments. Because of that it has trivialised them to the point where they think that they are akin to having your nails done. We did a survey with VICE a few years ago and 41,000 young people responded. Some 59% of those people said that they thought that dermal fillers and Botox were akin to having your nails done and there was no risk involved.
Social media companies enable practitioners to post about Botox and fillers freely. You cannot advertise those treatments via a paid-for post but you can create an organic post without being paid or sponsored and use the word Botox. There are 25 million posts with the hashtag #Botox that they could filter out. They filter out medical and reproductive things such as uterus and periods; you cannot post about that without them filtering it out. Yet you can use the hashtag #Botox and it is ubiquitous. For young people especially it is extremely toxic and dangerous.
It is not just Botox, fillers and all those things; it is harmful skincare ingredients that are now being targeted to children as young as eight who are wanting to go out and buy things such as retinols and acids, which are causing damage to their skin. Social media has a lot to answer for.
Nora Nugent: Ashton has covered the main points, but I would say we are now also seeing AI searches playing into it as well as social media. I would say the vast majority of people start their research by doing an online search or looking on social media. All the findings of a search are subject to what is out there. If what is out there is poor quality then their research is going to be poor quality. That is how people look for things nowadays and how the vast majority of people seeking aesthetic treatment start their research. They start online, whether it is a Google or AI search or Instagram, Facebook or TikTok, and the glossy platforms with lots of followers draw them in.
It is partly the standard of advertising and partly the use of filters, not standardised photographs. They are not even seeing a true picture of what is being done. It is glamourised, and it is as if it is a lunchtime procedure with no downside. There is a way of doing these things educationally and there is a way that is just pure marketing and exploitation. That is where we are at right now.
Q30 Kevin McKenna: A quick thing that just struck me is that we are talking about effectively invasive procedures, but some are injections and injectables. Injectables generally are becoming a much more common thing across society; I am not just thinking of weight loss jabs but this very grey and black area around peptides and steroids more generally. That is across gender as well. With this big growth and concern around these injectable peptides is there a link between all these things? Is all this being done by the same sets of people or are there different marketplaces for these different types of products?
Ashton Collins: It is part of the same problem, yet by and large it is the same sort of people who are responsible for these things. Social media enables people to set themselves up very quickly and easily as practitioners or sellers of these products and allows them equally to operate like ghosts. You can use spurious names, cause harm, disappear and reappear just as easily as anything else with different, equally spurious names. The amount of fake and unlicensed products—peptides, fat dissolvers, weight loss medications and Botox—that is now being sold and proliferated on social media is unfathomable. They are not doing enough to clamp down on it.
Nora Nugent: This is a very fast-moving side of medicine. I am calling it medicine deliberately because these are medical products with medical consequences. If we are talking about regulation, there also has to be some capacity to categorise new developments so that you do not bring out legislation and it is almost immediately out of date. There has to be some mechanism to categorise the procedures so that new procedures that come along would automatically fall under some level or section of the regulation. We have to think about that aspect in terms of bringing in regulation as well: not just what is out there now but what might come along, its level of invasiveness and risk and who should be doing it.
Q31 Kim Leadbeater: That feels as though we are playing catch-up in two worlds that move very quickly: the online world and, from what you are saying, the cosmetic procedures world as well, which is doubly difficult. On that note, have the Government done enough to educate the public about the risks of cosmetic procedures, and particularly the cosmetic tourism that Rosie talked about? If you do not think they have done enough, what more would you like to see them do?
Ashton Collins: While the Government have done awareness campaigns in the past they have been very fleeting. They tend to be one-off and run for very short periods of time, whereas this is something that needs an ongoing commitment. For us the biggest frustration is that whenever they are asked to comment on the back of a horror story in the news it is always, “Do your research; find an appropriate practitioner,” whereby the public do not know how to do that. If you are sat in front of somebody unscrupulous you can ask all the sensible questions that you want but they will tell you whatever to get your money.
We operate a Government-backed, Professional Standards Authority-accredited register whereby we inspect every single practitioner in every single clinic and take them through really robust assessment processes. Therefore I find it unfathomable why the Government do not direct the public to these registers to make safe and informed choices whereby if something goes wrong they have access to redress and complaints processes. For example if they were asked to comment on a gas safety issue, they would not just say, “Find a suitable gas engineer;” they would say, “Go to the Gas Safe Register.” There are lots of things that they could be doing now that would make such a meaningful and tangible difference to the people seeking these treatments.
Nora Nugent: I agree with what Ashton has said. In addition, from a cosmetic surgery tourism point of view, we know the countries that are most commonly involved, so they could work with the corresponding health and Government Departments in those countries as well. I know there has been work in the past, but I have not heard anything recently about progress. This needs to be something that is ongoing as well as public education. It needs to be multi-pronged and not a one-off campaign. This is something that you have to repeat over and over and over and almost have a long-running campaign or just a background constant campaign. One-off campaigns are fine at the time but the impact will wane and it will start up again. It has to be a sustained effort.
Q32 Kim Leadbeater: It sounds as though you think there should be more public awareness raising and an ongoing piece of work around that led by the Government.
Nora Nugent: Yes
Ashton Collins: If and when they bring in legislation it is useless without public awareness, so it would be beneficial for everybody.
Q33 Alex Brewer: Thank you both for giving your time and expertise today. If the Government were to publish their consultation tomorrow, what are the key changes that they must implement if patient safety is to improve?
Ashton Collins: From our perspective the urgency around restricting who can and cannot do these high-risk procedures is paramount. Had they listened to our calls for action in 2023, Alice Webb would still be alive. We cannot be in a situation where lay people are able to pick up scalpels and dissect people’s faces in living rooms; that is completely unacceptable and needs to be addressed as a matter of priority.
Nora Nugent: Ashton is absolutely right. The two key things are who can do what and where they can do it. It is not just about who is doing it but they have to do these procedures in a healthcare facility—whether it is a hospital or clinic depending on the level of procedure—in the right environment and with the right emergency processes and equipment available should the worst happen.
These procedures carry risks in qualified hands as well as unqualified hands. We would hope the risks are lower in qualified hands, and the ability to treat the risk is there as well. You have to be able to plan and be prepared for complications if you are going to do these treatments in the first place. It is not just about doing the treatment; it is about being able to have a backup plan and handle it if something goes wrong, regardless of who is doing it.
The best place to handle a complication is in a healthcare environment, not a beauty salon, hotel room, living room or a random building. You need emergency equipment available for things such as allergic reactions and someone who is able to prescribe for infections or dissolve fillers. All these things need to be in a healthcare environment. It is about who is doing it and where they are doing it and making sure that people are not going beyond their knowledge and skill levels.
Q34 Alex Brewer: Not to necessarily go over anything you have said already, but what would success look like in two years’ time in an ideal world?
Nora Nugent: That these procedures are off the high street and in healthcare environments, done by healthcare practitioners.
Ashton Collins: I sound like a broken record, and I am sure policymakers are sick of me saying this, but for the last 10 years I have been begging for the establishment of a dedicated taskforce. Oftentimes complaints involving these types of procedures are complex and require input from a vast array of different regulatory authorities, whether that be National Trading Standards, the MHRA, the statutory regulators, the ASA or whatever it might be.
Currently these people operate in silos. As I said, they do not take these complaints as seriously as they ought to, which means that current legislation is underpoliced and underenforced. I would like there to be much more accountability around the regulators that are responsible for policing and enforcing this legislation.
Q35 Alex Brewer: I do not want to end on too negative a note, but on the converse, what would concern you most if no legislation were passed before the end of this Parliament?
Nora Nugent: That we are still in the same situation and we have another death or more than one death. We have already had one on the non-surgical side and we have had surgical deaths. How many more do we need? Basically my concern is that the status quo continues.
Ashton Collins: Exactly that. My fear is that with every day that passes somebody else is going to lose their life at the hands of one of these unscrupulous people. Even in the case of Alice Webb, that police inquiry struggled to bring about charges in a timely fashion because of the lack of legislation surrounding these things.
Alex Brewer: That is very clear and articulate. Thank you very much indeed.
Chair: That concludes the inquiry for today. Thank you both very much for coming along.