The use of energy-based devices in non-surgical cosmetic treatments: risks and regulations

Introduction: This paper, prepared on behalf of the British Medical Laser Association (BMLA), provides informed responses to the Department of Health & Social Care (DHSC) consultation process made in July 2024 for the licensing of non-surgical cosmetic procedures in England, published under the 2022-2024 Sunak government. Methods: An evidence-based assessment of the risks associated with treatments performed using energy-based devices (EBDs), particularly laser and intense pulsed light (IPL) treatments, aims to inform the categories of such treatments and to help define a proportionate level of supervision. Results: Potential adverse incidents, including ocular injuries, skin reactions, and technical failures, are assessed and categorised into five types, with particular focus on operator errors, client non-compliance, and device malfunctions. The DHSC proposed levels of supervision of various non-surgical cosmetic procedures were reviewed, and a set of amended tables was developed for the oversight of laser and IPL. Summary: A review of case studies and scientific literature highlights the need for appropriate safety protocols, operator training to minimise complications and to ensure patient and operator protection. The BMLA proposes two categories of appropriate oversight for laser/IPL treatments, together with training recommendations for certified expert regulated healthcare professionals (ERHPs).