Working as a nurse in the cosmetic and aesthetic industry

In NSW currently, 1.7% of all notifications to the Nursing and Midwifery Council (NMC) are related to cosmetic/ aesthetic nursing practice.

Notification themes highlight concerns beyond those conventionally expected within the regulatory conduct, health and performance pathways. They raise issues regarding business processes, competitive practices, client expectations often seeking arbitration, advertising and social media. These are often provided to the regulator with 'before and after' photos in the hope that the regulator may intervene and assist with gaining financial compensation for the notifier.

Case study 

Ava* is a registered nurse who completed a new graduate program at a tertiary hospital in Sydney. Financial pressures were a catalyst for opening a business specialising in cosmetic injectables soon thereafter. Within 12 months of opening their business, a notification was made to the NMC by the Pharmaceutical Services Unit (PSU) relating to:

Breaches of the Poisons and Therapeutic Goods Act regarding: 

• storage of medication
• stocking unregistered therapeutic goods
• inadequate records of administration related to Schedule 4 cosmetic injections
• inadequate written direction authorising the supply/ administration of Schedule 4 cosmetic injections.

Concern for practising in a manner that is a contravention of the professional standard as a registered nurse:

• partly filled syringes without labels found on the premises
• possession of a pharmacy compounded therapeutic injectable containing Schedule 4 substances (not prescribed)
• evidence of single-use vials for solution for injection with multiple puncture marks.

Concern for breaches of National Law:

• Advertising compliance of a regulated health service.

In NSW, the NMC works in co-regulation with the Health Care Complaints Commission (HCCC). The Council contacted the practitioner directly and they acknowledged they were unaware of the NMBA position statement on nurses and cosmetic medical procedures or their responsibilities under the Poisons and therapeutic Goods Act 1996. They did not know they were doing anything wrong. They stated that working in cosmetic practice was very competitive and resolved to close their business down.

Following investigation by the HCCC, the practitioner closed the business and returned to practise within the acute care setting. The NMC resolution was to provide counselling before a committee of professional and community members and to close the matter.

For nurses working or thinking about practising in cosmetic/aesthetic practice, it is imperative you are aware of regulatory updates. A good starting place is the NMBA position statement on Nursing and cosmetic medical proceduresopen_in_new and the Poisons and Therapeutics Goods Act 1996open_in_new. If there is a notification made about your practice in this setting, you will be asked to provide further information on how you comply with these requirements.

Within this document you will find links to the NMBA’s standards, codes and guidelines which set the regulatory requirements within which nurses working in the area of cosmetic medical procedures must comply, to ensure ongoing competence and safe practice. Additionally, there is a link to the Medical Board of Australia’s (MBA) Guidelines for registered medical practitioners who perform cosmetic medical and surgical procedures (MBA guidelines). All nurses working in cosmetic medical procedures should be aware of the MBA guidelines.

_{*Not her real name}