January 30, 2025

Addressing the Risks of Unregulated Cosmetic Treatments: Why Compliance Matters in Aesthetic Medicine

Written by: Fresh Clinics

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Addressing the Risks of Unregulated Cosmetic Treatments: Why Compliance Matters in Aesthetic Medicine
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Over the weekend, reports emerged about three individuals in NSW being hospitalised after receiving botulinum toxin treatments. Notably, the treatments were done at residential premises by a non-healthcare practitioner with an unapproved variant of botulinum toxin.

The cases of botulism have sparked widespread concern and once again placed the aesthetics industry under scrutiny.

As expected, this has caused concern within the industry and among the public. However, while stories like this grab attention, they often fail to distinguish between illegal operators and highly trained, compliant medical professionals who prioritise patient safety.

While these incidents are alarming, they highlight the importance of regulatory compliance, training, and choosing authorised providers for cosmetic treatments. 

What is Botulism?

In an aesthetic context, botulism can occur if a sufficiently large dose of botulinum toxin is inadvertently administered. When a patient is injected with TGA-approved products (Dysport, Xeomin, Letybo, Nuceiva, and Botox are all approved for use in Australia by the TGA) by trained healthcare practitioners, developing botulism from cosmetic injectables is exceedingly rare.

The doses of these products used in aesthetics are generally not large enough to cause systemic symptoms and botulism, which can include:

  • Progressive weakness, particularly in the area of injections
  • Difficulty swallowing
  • Drooping eyelids
  • Blurred or double vision
  • Difficulty breathing

The unfortunate reality is that incidents like these can occur when unqualified individuals administer treatments without proper training or oversight. These unregistered individuals pose significant risks to those receiving treatments and often, as is the current case in NSW use non-TGA-approved or counterfeit products, improper dosing, and unsanitary conditions - all of which can lead to devastating severe complications including botulism.

Tips for Practitioners to Maintain Compliance 

Fresh Clinics works with and advocates for practitioners in the industry to uphold the highest standard of safety and care.  Some of the key actions that cosmetic nurses and doctors should follow to maintain compliance include:

  • Using TGA-approved S4 medications, including those approved products mentioned above (these can be sourced through Fresh Clinics)
  • Completing quarterly clinic compliance checks
  • Holding the correct council permits, and insurance, and maintaining up-to-date training
  • Keeping emergency S4 medications on site
  • Holding the correct poisons permits
  • Maintaining Ahpra registration 

Staying Updated on Compliance with Dr John Delaney and Dr John Holbrook

IMG_2704What Patients Should Look Out For

We encourage anyone considering aesthetic treatments to verify the qualifications of their practitioner and avoid risky, cheaper alternatives.

As Dr Jeremy McAnulty from NSW Health stated in the recent reports, botulism, while rare, can have life-threatening consequences. This is why it is vital for patients to:

  • Verify that their practitioner is qualified and registered with Ahpra
  • Ensure treatments are conducted in a clinical setting
  • Avoid unregulated "home jobs" or discounted services that may compromise safety

Fresh Clinics’ Dedication to Compliance and Safety

Fresh Clinics works tirelessly to maintain the highest standards of compliance and safety across every practitioner in our network.

We work exclusively with trained, licensed nurses and doctors who adhere to Australian regulatory requirements, including Ahpra,  Therapeutic Goods Administration (TGA) state Departments of Health, and local council standards and requirements. 

Every treatment authorised with Fresh Clinics is overseen by qualified medical doctors, ensuring that patients receive the care they can trust.

Our Members operate under strict compliance protocols, supported by software and systems designed to ensure patient safety and quality care:

  • Medical Directorship: Every treatment is supported by medical oversight, ensuring that all procedures are clinically appropriate and safe
  • Regulated Products: Our Members exclusively use TGA-approved S4 medications where sourced through Fresh Clinics
  • Complication Management: Should a complication arise, our doctors are available 24/7 to provide immediate advice and intervention

Fresh Clinics is the trusted partner for safe and compliant aesthetic treatments. We provide end-to-end support, from seamless telehealth consultations and regulatory compliance to complication management and training.

For patients, this means peace of mind knowing their treatments are performed by skilled professionals operating within a regulated framework. For practitioners, it means having the tools, knowledge, and support to thrive in a complex and evolving industry.

If you have questions about compliance or need support, reach out to our team today, call us, or schedule a time to chat below. 

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