Policing cosmetic treatments would be a tough job

However, concerns about how any such rules could be enforced have also been raised.

Cosmetic treatments such as botox, including at-home botox parties, and dermal fillers have grown in recent years.

There are concerns, though, that some treatments can be carried out by anyone without training.

Responding to a Scottish Government consultation on extending licensing, environmental health officers told West Lothian councillors that it is difficult to police what are “elective and voluntary procedures”.

Additional environmental health and licensing duties will put pressure on a council department struggling with its current load.

In a report to the executive, Craig Smith, the council’s environmental and trading standards manager, said: “Whilst the risks of harm to people choosing to undergo procedures is real and recognised, it is also recognised that many, if not most, procedures are elective and voluntary.

“It is difficult to fully support the introduction of these controls knowing that, in many cases, clients are putting themselves at risk out of choice, when local authorities do not have adequate resources to protect wider public health and safety in other higher priority areas of work.”

Currently some procedures are licensed under the Civic Government (Scotland) Act 1982. These include skin piercing, tattooing and micro-blading (creating semi-permanent eyebrows by colouring cuts in the skin).

However, there are an ever increasing number of treatments, known as non-surgical cosmetic procedures (NSCP), which fall outwith the scope.

If they are not carried out by medical practitioners, regulated by Healthcare Inspectorate Scotland (HIS), they are more or less unregulated. The consultation asks for views on the proposed controls on NSCP.

These include biotherapy, or injections of any products derived from the patient’s blood; injections to treat varicose veins, dermal micro-coring or skin removal; the removal of skin tags, or any procedure which removes fat or fluid intravenously.

These are procedures which Holyrood suggests should only be carried out in either an independent clinic or other healthcare setting regulated by HIS or licensed by the local authority.

It also suggests that wherever procedures take place they should be carried out by a suitably trained and qualified practitioner or a healthcare professional.

The report to the executive said: “Whilst there are clearly concerns regarding the unregulated aspects of NSCPs, any new requirements for licensing or control will place additional burdens on local authorities.

“Legal services administer the licences for skin piercing etc, with environmental health carrying out the necessary inspections.

“Even if local authorities apply charges for licensing, it is unlikely to provide any additional staff resource to address work demands.”​​​​​​​​​​​​​​​​​​​​​

The executive agreed with the officer response to the Holyrood consultation.