At Long Last! Guidance from the GMC and RCS finally protects patients from high-risk cosmetic procedures! Or does it?

In this post, Melanie Latham (Manchester Metropolitan University) reflects on new guidance for cosmetic practitioners - does it go far enough?

New guidance for cosmetic practitioners published this week by two important medical bodies has been desperately needed in the UK for several years.  It should go a long way to protect patients.



The General Medical Council’s (GMC) long-awaited guidance for cosmetic practitioners in the UK, “Guidance for doctors who offer cosmetic interventions”, comes into force in June 2016.  This is to be read alongside today’s publication from the Royal College of Surgeons (RCS) “Professional Standards for Cosmetic Surgery”, which concentrates on cosmetic surgery. 

The new GMC guidance covers both surgical and non-surgical procedures, so facelifts, but also Botox.  It makes recommendations to practitioners about what they should do to practice professionally and refers to advertising; a cooling-off period; consent; after-care; safe record-keeping; and the vulnerability of young patients.

The GMC guidance says in more detail that doctors must:

Advertise and market services responsibly – any advertising must be clear, factual, and not use promotional tactics, such as ‘two-for-one’ offers to encourage patients to make ill-considered decisions. It also includes a ban on offering procedures as prizes. Doctors must not allow others to misrepresent their services.



Give patients time for reflection – a cooling-off period – make sure they have the time and information about risks, to decide whether to go ahead with a procedure. Patients should not feel rushed or pressured.

Seek a patient’s consent themselves – the doctor carrying out a cosmetic procedure is responsible for discussing it with the patient, providing them with the information and support they need, and for obtaining their consent. This responsibility must not be delegated.

Provide continuity of care – the doctor must make sure patients know who to contact and how their care will be managed if they experience any complications, and that they have full details of any medicines or implants.

Support patient safety – making full and accurate records of consultations, using systems to identify and act on any patient safety concerns, and contributing to programmes to monitor quality and outcomes, including registers for devices such as breast implants.

The Royal College of Surgeons also recommends that: cosmetic surgeons should be certified in the area of surgery in which they practice, practice safely, and keep accurate records; the operating surgeon should lead the consultation with the patient and obtain their written consent; there should be a two week cooling-off period; indemnity insurance; and no financial inducements. 

Both the GMC and RCS emphasise:- the importance of training, safety, fully informed consent, a cooling-off period, capacity and young people, after-care, record keeping, and teamwork. 

All these things are of fundamental importance.  However, are the GMC or the RCS doing enough? 


We must not forget that the risks of cosmetic surgery are akin to other types of surgery – bruising, heavy blood loss, infection, pulmonary oedema, even death.  Cosmetic medicine (e.g Botox) can also risk scars, bruising, and permanent disfigurement.  Yet what is worse is that the patient who risks these things – and pays a high financial price, if not a physical one – is operated on in an atmosphere ruled by profit.  The smiling receptionist – the silver tongued salesman – the well-spoken and white-coated doctor – they all sell and profit from the myriad of cosmetic procedures currently available from facelifts to Botox, breast implants to dermal fillers.  They are almost bound to put a sugar coating on any information they give to prospective patients.



The UK government must go further than the GMC and RCS guidance published this week.  They must establish one much-needed ‘umbrella body’, equivalent to a Cosmetic Procedure Authority, of which all cosmetic practitioners must be members, to oversee the practice of cosmetic procedures by an industry that is extremely profitable yet barely regulated.  Such a body is still urgently needed to provide independent and objective information about the risks of cosmetic procedures; the qualifications needed to carry them out; who has a good track record of doing so; and how to check whether practitioners are insured.  Its membership should contain lay persons, perhaps including those who have undergone a cosmetic procedure, and perhaps those who could represent the views of patients themselves.  Such a body would go even further to protect patients from the risks of cosmetic procedures.


Melanie Latham is a Reader in Law at Manchester Metropolitan University. Her research interests have become delineated by ideas around autonomy, rights and gender and are focussed currently upon the regulation of cosmetic surgery and patient autonomy. She sees cosmetic surgery as an increasingly popular medical treatment for women that can pose challenges for ideas around culture and agency. Her research also extends to the fields of body modification, aesthetics, feminist ethics, nanotechnology regulation, and climate change. 

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