TGA’s new cosmetic ad ban won’t protect the public

5 minute read

Now phrases like ‘dermal fillers’ and ‘anti-wrinkle injections’ are forbidden, where does the TGA think people will look?

Is this the beginning of the end of the non-surgical cosmetic boom in Australia?

This month businesses in the medical aesthetics industry were surprised to receive an email from the Therapeutic Goods Administration advising of further changes to the way we may advertise services.

It seems that on 18 December, without consultation or warning, the TGA decided that commonly used terms such as “anti-wrinkle injections” and “dermal fillers”, used to explain the way different drugs work without using brand names, were no longer allowed.

The TGA advised that this was “because these terms refer to (by drawing the audience’s mind to) prescription-only products” (see letter below). Alternative terms that we may use are still pending from the TGA. Its website on these changes says only that the appropriate terms will be advised in due time.

To say this has caused alarm would be an understatement, especially given the lack of warning.

The Australasian Society of Aesthetic Plastic Surgeons has called the TGA unprofessional for having done this without prior consultation. Many practitioners are worried that without the ability to use even generic descriptors, we will be unable to educate the public who are already confused given we cannot legally use drug names.

I emailed the TGA my concerns – namely, that while I agree with the idea of regulating the industry as a whole by means of an entry standard (currently very very low), a training pathway and ongoing supervision/mentorship, this will likely miss the mark for several reasons.

When drugs go viral – such as the popular weight loss injectable that has been in short supply for more than a year now – the argument that it’s inducing vulnerable patients no longer applies because we all have access to a global network for information on drugs including their names.

Limiting what Australian healthcare workers can or cannot say and name simply means that patients will source their education from overseas providers, who may not even be doctors or nurses, or who may be talking about similar yet different drugs which may not be registered with the TGA here such as in the USA and elsewhere.

As I’ve discussed before, one of my biggest reasons for putting myself on social media during covid and since, is my belief that in the absence of reliable, expert education from someone actually qualified to do so, influencers and healthcare workers with vested interests step in to fill the void, often selling snake oil, and the public knows no different. Is this what the TGA is intending by these new rules?

Making a regulated drug invisible in regulated medical circles doesn’t mean people stop using it or looking for it; it simply drives it “underground” and means they find ways to access it in unsafe ways, via unsafe providers who are often in it purely for the money.

I understand and share the TGA’s and AHPRA’s concerns about this sector:

As healthcare workers many of us have allowed our standards to slip.

As healthcare workers many of us are minimally qualified, with people studying nursing just to get into injecting and doctors skipping speciality training to inject post mandatory internship.

As healthcare workers, when we have not been part of a multi-disciplinary team and don’t know the importance of working within one, for our own safety and that of our patients, we resort to working alone after a “boot camp” of mere days and fall into the trap of being retail salespersons.

As healthcare workers, we are not immune to the lure of “quick” and “easy” money when the alternative slog is so exhausting.

The solution to all this, however, is not to further curtail education by people who are actually qualified to inform and to educate to help keep people safe.

Medical aesthetics, like weight-loss drugs, are here to stay in the media space. This horse has long bolted. Regulations such as the ones that came into effect in July 2023 have not stopped rogue injectors from continuing to work dishonestly to induce the public. They have stopped ethical workers from continuing to educate on what safe and good aesthetics might look like.

I’ve heard anecdotally that the regulations on cosmetic surgery since July 2023 has meant that more people are flying overseas for their surgery. If something goes wrong upon return home, the surgeons here are nonetheless left to carry the can. How is this protection for the public?

If this ban by the TGA is upheld, what will likely happen is that rogue operators will continue to work with impunity and risk the fines, since the TGA and AHPRA rely on people reporting them and their profits make the fines risible. Providers not limited by AHPRA registration and obligations will step into this space to sell unproven therapies and confuse patients further, risking harm.

Medical aesthetics at present is the only speciality in medicine that bypasses a recognised training program with an entry standard, mandatory supervision and training and work within a multi-disciplinary team for a minimum time frame for the benefit of both patient and providers.

For too long, medical aesthetics has been (wrongly) seen as the option that people can choose when they can’t or don’t want to do “real” nursing or medicine because the bar is so low. It is a complex speciality with rare but real risks and dangers and I’m regularly appalled at the lack of knowledge and standards in the industry.

But this kneejerk response by the TGA risks making matters worse for patient safety.

Removal of reasonable access, including expert information, does not cause compliance but pushes the service underground into the hands of unscrupulous providers. Online menopausal services are one example of these, online weight loss services are another.

Is this really where we want to be going with medical aesthetics?

Dr Imaan Joshi is a Sydney GP whose practice includes aesthetics; she tweets @imaanjoshi.

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