I am getting really confused as according to the CTIA website they have a prescription service which I quote is " [FONT=Arial, Helvetica, sans-serif][SIZE=-1] in accordance with the Law and the CTIA prescribing policy which has been accepted by MHRA", so who is right here? It sounds credible and supportive, so why should any BT not believe it?[/SIZE][/FONT]
I would say the Nursing and Midwifery Council (NMC) are right here. Their guidance on their website is unequivocally clear that a person administering botox from a prescription where the prescriber (be that a doctor or and independent nurse prescriber) hasn't seen the patient face to face, then this constitutes a 'remote' prescription.
As is the General Medical Council (GMC). These bodies legally control and monitor nurses and doctors practice and are separate from the MHRA. It is a combination of these bodies and legal guidance that is used.
Botox is a prescription only medicine and can only be administered from a prescription.
The grey area only seems to come from two things (to my knowledge so far).
1. A prescriber can instruct anyone to administer a prescription medication.
2. Potentially (and this is because this hasn't yet been 'tested' in law), botox "could" be administered via a remote prescription for 'medical' reasons such as excessive sweating (hyperhidrosis) or where the treatment could be deemed as medical for example, if someone's appearance and wrinkles were deemed to be causing a significant mental health issue etc.
The NMC recently clarified their stance on botox, HOWEVER one thing people seem to miss is that they have ALWAYS said a remote prescription should only be used in emergencies.
To put it into context, if a nurse was working in a ward on a night shift and a patient became very unwell and needed some urgent medication, but because there was only one doctor and he/she was dealing with another emergency, they could bleep that doctor and they could direct the nurse to administer a drug over the phone. In this situation it is sensible and right not to delay the administration of a drug because there is no immediate written prescription available.
However, the routine use of botox as a cosmetic treatment is so far removed from this situation that any Nurse or BT administering botox in this way leaves themselves wide open to potential criminal prosecution.
Is it really worth it?
I suspect, although this is my opinion, that the companies out there saying 'MHRA approved' are potentially bending the rules a little and claiming the treatment is 'medical'. I don't know but thats the only way i can see they get around it.
But the bottom line is really that this is an area that is complex and difficult enough for registered qualified nurses to work in if they are not prescribers, therefore for beauty therapists to even contemplate this, in my view is unbelievable.
Even though fillers are classed as 'medical devices' not drugs, I still feel BT's do not and will never have the correct training and experience to administer them. After all, you are injecting a substance under the skin on someones face, the most visible part of the body, essential for communication so the stakes are pretty high if things go wrong!
Its not about being elitist, or bullying people into submission or saying'you cant do this you cant do that'. It's about getting the right advice, training, legal protection and overall service to the clients who deserve to be treated by appropriately trained and experienced aesthetic practitioners.
I suspect we will see a raft of legal cases, like with the General Dental Council on teeth whitening, come about in the near future with this. (A man got fined in excess of £5000 for whitening teeth as he falsely believed it was a 'cosmetic' treatment not a dental treatment.)
Who would want that!?
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