Enter the cosmetic world, a world filled with exemptions and clarifications to the CQC (Care Quality Commission) to establish if your cosmetic treatments do or do not fall under Regulated Activity. Does the category of Laser you currently use fall under the CQC regulations? Have you checked? Do you know what requirements you will need to fulfil to be a CQC provider?
Whether you do or do not fall under the CQC, the CQC has identified some key trending concerns that all cosmetic providers should strive to address to ensure that patient safety is at the top of your priority list as a business.
So, what are they? How can I address them?
- Training
Staff carrying out their role without the expertise or competency.
- Have an established recruitment process including acquiring references for all staff members
- Hold training records for all staff members
- Conduct bone fide checks on your staff members: GMC, GPhC, GDC, NMC, DBS
- Induction training including health and safety training
- Patient safety training including emergency situations, basic life support, anaphylaxis, safeguarding
- Test competency with questionnaires, supervision and observations
- Assessment of all job roles and the training they require; infections control lead, emergency first aider, fire warden, health and safety officer, chaperone etc.
- Retain all records and certificates for future review
- Ensure update training is carried out to keep all staff members up to date.
- Sedation and Anaesthetics use, safety processes, governance, risk management and patient safety
Unsafe practices when using sedation or anaesthetics. Failure to monitor and manage patients effectively post-treatment. Poor governance, safety and risk management processes. Ultimately a failure to embed local and national guidelines into the standard operating procedures to ensure all staff members operate to the same standard.
- Ensure all staff members are comprehensively trained and competent to carry out this role
- Standard Operating Procedures implemented, imbedded and maintained to ensure all staff members are operating to the same standard following local and national guidelines
- Observations of all staff members to ensure safe practices
- Ensure systems remain up to date when legislation or guidance changes and update training is carried out
- Encourage an open and honest environment where staff members feel confident to report observed unsafe practices without repercussion
- Effective medicine management including temperature controls and maintaining product specifications
- Strong governance framework in place including arrangements to monitor and improve quality and identify risk areas
- Internal audits carried out to assess the effectiveness and implement improvements
- Patient inclusion to assess the likelihood of an adverse reaction or deterioration after treatment so proactive rather than reactive approach to patient care.
- Consent
Providers are failing to ensure there is a sufficient cooling-off period between the initial consultation and surgery/treatment, therefore, failing to implement a two-stage process to consent
- Ensure all staff members are comprehensively trained and competent to carry out this role
- Establish a concrete process for consent using a Standard Operating Procedure which is then implemented, imbedded and maintained to ensure all staff members are operating to the same standard following local and national guidelines
- Use written consent forms to illustrate the cooling-off period between the first and second appointment and retain for future reference
- Observations of all staff members to ensure safe practices
- Ensure systems remain up to date when legislation or guidance changes and update training is carried out
- Encourage an open and honest environment where staff members feel confident to report observed unsafe practices without repercussion
- Ensure an assessment for Mental Capacity is completed at each appointment
- Infection control and prevention
- Ensure all staff members are comprehensively trained in infection control and prevention
- Appoint an infection control lead
- Carry out a robust risk assessment on infection risks in the clinic and control the risks identified
- Standard Operating Procedures implemented, imbedded and maintained to ensure all staff members are operating to the same standard following local and national guidelines including the minimisation of infection
- Observations of all staff members to ensure safe practices
- Ensure systems remain up to date when legislation or guidance changes and update training is carried out
- Encourage an open and honest environment where staff members feel confident to report observed unsafe practices without repercussion
- Equipment maintenance
- Ensure there is a standard operating procedure for the maintenance of all equipment on-site including fridges if used for medicinal products
- Ensure there is a qualifying and validation process in place for all new equipment
- Ensure there is a maintenance schedule established for all equipment that requires maintenance or servicing
- Ensure all fridges are temperature mapped to assess suitability for medicinal storage
- Ensure one person is responsible for adhering to the maintenance schedule
- Retain all records of maintenance for future reference
Whether your company requires or does not require a CQC registration ensure your activity adopts the most up to date guidelines and legislation is fundamental for compliance and ultimately protecting your patients’ safety and the company from future litigation. If you require any information or advice on CQC or safety standards feel free to contact us today to discuss your requirements.