There are growing tensions in the cosmetic industry between nurses and doctors over who should be allowed to administer Botox.
Doctors have said nurses should only inject Botox when a doctor is in the building, but nurses argue that they administer prescription medications in all areas of the health service without having a doctor on site.
Under the law, Botox must be prescribed and administered by a doctor or a dentist.
The law states that a doctor or dentist may direct a registered nurse to administer a prescription medicine to a patient. However, there is confusion over what "under the direction of" a doctor means.
Call for clarity on laws surrounding Botox
The Irish College of Aesthetic Medicine said the law is open to interpretation and is calling for clarity from regulators.
President of the Irish College of Aesthetic Medicine Dr Sean Fitzpatrick said nurses should only be allowed to administer Botox when a doctor is present in a clinic.
He said: "In a situation where you have the administration of a prescription medication, if something goes wrong, whether it’s an anaphylaxis, an infection, it requires a prescription medication, it requires immediate intervention by a doctor, if the doctor is not in house then it is a patient safety issue."
However, nurses have argued that they are more than capable of administering Botox without a doctor being onsite.
Chairperson of the Dermatology Aesthetic Nurses Association of Ireland Christina O'Rourke said: "If a nurse is safe to administer a medication in a community setting in a nursing home without a doctor physically present why is it required in a dermatology aesthetic setting."
Ms O'Rourke said nurses administering medication are trained in the management of anaphylaxis, which is a potential life-threatening allergic reaction.
"There would be strict expectations for nurses to have … before administering medication of any description, to have an awareness and a study of anaphylaxis, this would include several medication management documents that are considered essential," she said.
Nurses 'already administering Botox without doctor'
Dr Lisa Cunningham, a consultant in emergency medicine and aesthetic practitioner in Mayo, said nurses are already administering Botox in the health service every day without the need for a doctor onsite.
She said: "Botulinum Toxin is a prescription only medicine, so prescription only medicines are administered every day in our public system and our private system every day by registered nurses, advanced nurse practitioners and clinical nurse specialists, without the doctor physically being on site for those applications.
"They are normally done in a consultant led or a doctor led service and we see this everyday either in the emergency department, in oncology services, endocrinology, gastro, dermatology, all our systems would work with this already, so our nurse practitioners are able to deliver prescription only medicines without the doctor necessarily being right beside the nurse practitioner."
However, Dr Fitzpatrick said nurses administering Botox "must be closely supervised by a doctor".
"Nurses administer medications in hospitals in wards, out in the community, but in all of those situations there is always a doctor on call, in the hospital at 2am in the morning, there is an intern, a senior house officer, a registrar, a consultant, all available to intervene immediately if something goes wrong.
"Likewise in the community you have GPs on call who are supervising those medications and are responsible for intervening - this is not a like for like comparison."
'Unqualified cowboy injectors'
However, in a statement the Irish College of Aesthetic Medicine said: "The real danger in the industry is not trained nurses and doctors providing Botox, it’s the unqualified cowboy injectors dressed up like doctors in scrubs wielding worthless certificates and posing a serious risk to public safety."
Dr Fitzpatrick, said the Irish College of Aesthetic Medicine group is willing to work with nurses to come up with a solution.
He said: "The main issue is the non-medics, the people who have no medical background, the hair-dressers, the nail technicians, who open up dermal filler clinics in the backstreet of a house, they’re the real concern here.
"That’s what we’re really going after, squabbling between doctors and nurses over who gets to administer Botox, that is the battle, there is a bigger picture here."
The Dermatology Aesthetic Nurses Association said: "DANAI nurses have campaigned over 15 years for the statutory regulation of the aesthetic industry in Ireland. While our main concern is the public health risk posed by unregulated practitioners, we will continue to lead the call for best practice standards among doctors and nurses. Aesthetic practice will never be too safe."
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In a statement, the Health Products Regulatory Authority (HPRA), which regulates Botox, said it does not have a role in the regulation of healthcare professionals injecting Botox.
It said the supervision of this administration is a matter for the professional regulatory bodies.
The Nursing and Midwifery Board of Ireland (NMBI), which oversees the regulation of nurses, said it is aware that there is a demand for further clarity surrounding Botox administration and is working to provide that clarity.
The Medical Council said it is working with both the HPRA and the NMBI on how they can approach these issues as regulators, to ensure that patient safety remains a priority.
In the absence of clear legislation, Dr Fitzpatrick said the law is open to interpretation and has called for more clarity from regulators.
He said: "At the moment ICAM finds it unacceptable that we still have this grey area around a clear and present patient safety issue, so we need clarity from the Health Products Regulatory Authority."
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