Aesthetic procedure safety policy (private clinic)

1. Purpose

This policy sets out how the Clinic manages safety for non-surgical aesthetic procedures.

It covers botulinum toxin, dermal fillers, product traceability, prescribing routes, anatomical risk review, complication response, Yellow Card reporting and patient selection.

2. Sources to verify before adoption

GMC, Guidance for doctors who offer cosmetic interventions: https://www.gmc-uk.org/professional-standards/the-professional-standards/cosmetic-interventions
GMC, Good practice in prescribing and managing medicines and devices: https://www.gmc-uk.org/professional-standards/professional-standards-for-doctors/good-practice-in-prescribing-and-managing-medicines-and-devices
Botulinum Toxin and Cosmetic Fillers (Children) Act 2021: https://www.legislation.gov.uk/ukpga/2021/19/contents
Human Medicines Regulations 2012: https://www.legislation.gov.uk/uksi/2012/1916/contents
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 12: https://www.legislation.gov.uk/uksi/2014/2936/regulation/12
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 17: https://www.legislation.gov.uk/uksi/2014/2936/regulation/17
MHRA Yellow Card scheme: https://yellowcard.mhra.gov.uk/
General Pharmaceutical Council: https://www.pharmacyregulation.org/
Joint Council for Cosmetic Practitioners: https://www.jccp.org.uk/
Cosmetic Practice Standards Authority: https://www.cosmeticstandards.org.uk/

3. Scope

This policy applies to:

botulinum toxin treatment
dermal filler treatment
other injectable aesthetic treatments
prescription-only medicines used for aesthetic procedures
aesthetic medical devices and products
patient selection for aesthetic procedures
complication recognition and escalation
emergency reversal or rescue arrangements where relevant
post-procedure review
adverse-event reporting

The Clinic does not allow a product, device or medicine to be used unless the Consultant has approved it for the Clinic's service, scope and staff competence.

4. Aesthetic procedure process

The Clinic follows a documented process for every aesthetic procedure.

4.1 Patient selection

The Aesthetic Practitioner or Consultant assesses:

reason for treatment
expected outcome
previous aesthetic procedures
current medicines
allergy and adverse reaction history
pregnancy or breastfeeding status where relevant
medical contraindications
signs of coercion or pressure
unrealistic expectations
body image concern or mental-health concern
aftercare ability

Where the assessment raises concern, the procedure is paused and the Consultant reviews the patient.

4.2 Product and prescribing checks

The Clinic records the lawful route for each product or medicine.

The check covers:

whether the product is a prescription-only medicine
prescriber identity where required
patient-specific assessment
product name
batch number
expiry date
supplier
storage condition
recall route
who may administer it
training required

Staff do not use stock supplied by the patient or by an unapproved supplier.

4.3 Anatomical safety review

Before injection or treatment, the clinician reviews anatomical risks for the treatment area.

The local procedure covers:

treatment area marking where relevant
vascular occlusion risk for fillers
glabella, nose, forehead and periorbital caution where relevant
aspiration or cannula technique where local protocol requires it
dose or volume limit
product placement depth
patient positioning
escalation route if unexpected pain, blanching, visual symptoms or skin change occurs

The Clinic verifies technique and anatomical protocols against current professional source material before adoption.

5. Complication response

The Clinic keeps a written complication-response pathway.

5.1 Immediate complications

If Staff identify an immediate complication, they:

stop the procedure
make the patient safe
call the Consultant or senior clinician
follow the product-specific complication pathway
call 999 where urgent transfer is required
record symptoms, timing, product, dose, area and action taken
preserve product and batch information
arrange follow-up

The Clinic does not treat a complication as a cosmetic dissatisfaction complaint until clinical harm has been excluded.

5.2 Dermal filler vascular concern

The Clinic keeps a filler vascular-event response pathway where it provides dermal fillers.

The pathway covers:

recognition of severe pain, blanching, livedo, visual symptoms or delayed skin change
immediate senior clinical review
hyaluronidase availability where the Clinic provides hyaluronic acid fillers
emergency referral route
patient follow-up
incident recording
product and batch traceability

The Clinic verifies hyaluronidase storage, prescribing, dosing and training against current clinical source material before adoption.

5.3 Botulinum toxin adverse event

If a botulinum toxin adverse event occurs, the Clinic records:

indication and treatment area
product and batch number
dose
dilution where relevant
symptoms and timing
treatment or advice given
follow-up arrangements
MHRA Yellow Card decision

The Consultant reviews repeated asymmetry, ptosis, systemic reaction or patient harm trends.

6. Product traceability and recall

The Clinic keeps traceability records for aesthetic products.

Records allow the Clinic to identify every patient treated with a specific product or batch where there is a recall, safety concern or regulatory enquiry.

If a recall or safety alert is received, Staff:

identify affected stock
quarantine stock
identify affected patients where required
contact the Consultant
record the action taken
consider external reporting
assign improvement action where governance changes are needed

7. Responsibilities

Registered Manager: owns this policy, ensures governance oversight and signs off annual review.
Consultant: approves products, prescribing routes, complication pathways and clinical escalation.
Aesthetic Practitioner: completes patient selection, procedure records, traceability records and complication escalation within competence.
Clinic Nurse: supports stock checks, product quarantine, observations and patient follow-up where within role.
Administration staff: support recall contact and appointment scheduling but do not give clinical advice.
All staff: report product defects, adverse events, recall notices and unsafe practice immediately.

8. Recording requirements

The Clinic keeps the following records:

patient selection assessment
consent record
product approval record
prescription or lawful supply record
product name, batch number and expiry date
injection or treatment map
dose or volume record
adverse-event record
complication pathway record
MHRA Yellow Card decision
recall or quarantine record
follow-up record
staff competency record
improvement action record

Records are kept in the clinical record and Clinic governance records according to local procedure.

9. Audit cadence

The Clinic uses the following Verivius default audit rhythm unless current source material requires a different rhythm:

Monthly: the Clinic Nurse checks aesthetic product stock, expiry dates, storage and recall notices.
Quarterly: the Consultant audits consent, product traceability, complication records and patient selection concerns.
Annually: the Registered Manager reviews this policy against current GMC, MHRA, JCCP, CPSA and CQC source material.

Audit findings are recorded as improvement actions with an owner and review date.

10. Version control and review date

The Clinic keeps a controlled copy of this policy. The footer or document-control table records:

policy owner
version number
date approved
next review date
changes made since the last version
source material checked during the review

11. Related records

Cosmetic consent and cooling-off period policy
Product approval list
Prescribing record
Treatment map
Product traceability log
Recall log
Incident register
MHRA Yellow Card record
Training matrix
Improvement action register

Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.