MSPs are due to vote on a new Scottish Government bill tomorrow on cosmetic procedures. Here Dr Darren McKeown, who describes himself as one of the most experienced facial aesthetic medical practitioners in the UK, says the current regulatory vacuum is costing lives.

The death of Alice Webb, following a so-called “liquid BBL” procedure allegedly carried out by Jordan Park, should have been a moment of national reckoning.

Instead, it was just another passing news story in an industry that has been allowed to operate in regulatory chaos for far too long. Now, facing the prospect of criminal charges, Jordan Park - the non-healthcare practitioner who performed the procedure, has also died. 

As a doctor working in aesthetic medicine, I am not shocked by this tragedy. I am angry. Angry that it was predictable. Angry that it was preventable. And angry that successive governments have failed to act with the urgency required to protect the public.

Let me be clear: this is not simply about one practitioner making a catastrophic error. This is about a regulatory vacuum that allowed someone without appropriate medical training to perform an invasive, high-risk cosmetic procedure. That vacuum is the responsibility of government and they have blood on their hands this morning for all of the victims. It is not only the two tragic deaths, but the hundreds or perhaps thousands of mainly women around the country who have been left scarred for life as a result of unregulated cosmetic procedures. 

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In medicine, we are trained for years - decades even - to properly understand anatomy, physiology, pharmacology, complications and risk management. We are trained not only in what to do — but in what not to do. We understand human biology on a very intuitive level. The location of major blood vessels. The dangers of intravascular injection. The catastrophic consequences of embolism.

The procedure that Park is believed to have performed on mother-of-five Alice Webb, a so-called “liquid BBL” involves injecting a large volume of hyaluronic acid into the buttocks. It is not a beauty treatment. It is an invasive medical procedure with well-documented risks, including vascular compromise and fatal embolic events.

The problem for Park, and many others like him, is that you simply don’t know what you don’t know. 

If someone is not medically trained, how can they possibly understand the risks they cannot see? How can they recognise when they are in dangerous territory? How can they know when to stop?

That is precisely why regulation exists. Regulation is not there to stifle enterprise. It is there to prevent people from undertaking dangerous acts without insight into the consequences.

In Scotland, legislation is currently progressing that will limit the ability of non-healthcare professionals to perform certain aesthetic procedures. That is welcome. But it does not go far enough, and it has come far too late. The government still want to allow non-healthcare professionals to perform invasive injectable procedures, so long as they are ‘supervised’ in a clinic environment. This bizarre proposal has no international precedent.

What troubles me deeply is the newspapers in recent days have been pushing the argument that tighter regulation will “limit women in business” or damage entrepreneurship in the beauty sector.

The United Kingdom, including Scotland, is out of step with international standards., believes Dr McKeown (Image: Getty)

That argument cuts no mustard.

The majority of healthcare-led aesthetic clinics are run by women. Regulation does not disadvantage women. It disadvantages the unqualified.

Public safety should never be weighed against perceived economic impact. We do not allow unlicensed individuals to practise dentistry because it might support small businesses. We do not allow untrained individuals to perform other types of medical procedures because it creates jobs. We regulate professions precisely because lives are at stake.

Why should aesthetic medicine be treated differently?

The United Kingdom, including Scotland, is out of step with international standards. In every other country in Europe, every state in America and Australia, invasive cosmetic procedures are clearly defined as medical acts and restricted accordingly. In other countries people go to jail for doing what beauticians set up shop and do on our local high streets. 

When people die, there is a temptation to personalise blame. I do not blame Jordan Park for Alice Webb’s death. I blame the government and their lack of action. Of course, individuals must be accountable for their actions. But Park was only allowed to exist in doing what he was doing because of the governments failures. 

In my view, both Jordan Park and Alice Webb are victims of that defective system.

They paid with their life. 

Neither outcome should ever have been possible.

We regulate prescription medicines. We regulate medical devices. We regulate who can practice medicine. We’ve just never defined what any of those mean which has allowed a multi-million-pound injectable industry to operate in a grey zone where invasive procedures can be carried out by individuals without medical qualifications.

That is indefensible.

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The solution is not complicated. Invasive injectable procedures should be legally defined as medical treatments. They should be performed only by appropriately trained, regulated healthcare professionals. There should be no loopholes that allow the unqualified to continue performing these procedures - under loosely defined ‘supervision’ or otherwise. 

Scotland is at an important point in bringing forward legislation. Our politicians now need to grow a backbone, prioritise patient safety and vote for the amendments to the bill that prioritise patient safety by having injectable procedures only performed by regulated healthcare professionals. Unless they do that, we will continue to see harm and Scotland will continue to be at odds with the rest of the international community. 

This is not about aesthetics versus medicine. It is about patient safety. It is about acknowledging that once you breach the skin and introduce medical substances into the body, you are practising medicine — whether you call it beauty or not.

The government can no longer hide behind half baked solutions. Two people are dead. The fact they died in the north of England rather than Scotland is simply a fluke of geography. The regulatory environment in both places is the same. 

If regulation had been in place years ago — robust, enforceable regulation — neither of them would have ended up dead.

It’s now over to our politicians to make sure there is no more preventable harm in Scotland. 

© Herald Scotland