Leading Plastic Surgeon urges the MHRA to clarify its stance on whether Nurses can administer Botox and if it can be mentioned on websites.
Mr Adrian Richards, Clinical Director of Cosmetic Courses has called for the Government controlled MHRA to clarify it stance on two major issues. Are Nurses allowed to administer Botox injections without the patient seeing a doctor or dentist and whether the term Botox can be used on websites? Mr Richards stated that because the MHRA recommendations are not being enforced they are being widely ignored throughout the UK.
The MHRA- Medicines and Healthcare regulatory Agency is the government body “designed to ensure that Medicines and Medical devices are acceptably safe”. As such it regulates the use of all prescription only (POM’s) including Botox.
The MHRA’s guidelines state that Botox “can be administered by an appropriate practitioner or under the guidance of an appropriate practitioner”. By this they mean a Doctor, Dentist or Nurse who has completed extra training to allow them to prescribe Botox.
Mr Richards however feels that the MHRA phrase “under the guidance of an appropriate practitioner” is unnecessarily woollen and can be interpreted in many different ways.
The Nursing and Midwifery Council (NMC) have stated that they do not consider it good practice for nurses to administer Botox via a remote consultation. They recommend that each patient is reviewed in person by a Doctor or Dentist prior to treatment.
This is not specifically stated as a recommendation by the MHRA. This has resulted in some Nurses abiding by the NMC recommendations but many ignoring them completely and administering Botox injections with no contact with an “Appropriate practitioner”
Mr Richards stated that the MHRA guidelines are being widely ignored with impunity because no Nurse has yet been prosecuted by the MHRA for repeatedly ignoring their recommendations.
Likewise advertising prescription only medicines such as Botox is illegal. However many websites feature Botox heavily on their home pages. The MHRA’s role is to enforce this but again Mr Richards said that these companies were ignoring the recommendations because the MHRA have never taken any legal action against them.
Mr Richards urged the MHRA to clarify both of these issues as soon as possible to ensure that Botox treatments are as safe as possible and administered by appropriate practitioners.





