Nadine Dilong It’s a heated debate.
It’s fair to say that no other regulation change in recent times has quite received the same surprised and disappointed reaction from the vast majority of practitioners, like the TGA’s announcement earlier this week that new, stricter advertising guidelines have come into effect.
Arguing that referring to prescription only products as ‘anti-wrinkle injection’ and ‘dermal filler’ draws the consumer’s mind to well-known schedule-4 drugs, the TGA has now banned the use of said terms.
Arguments Against Stricter Guidelines
When we broke the news on Tuesday this week, it became very clear that most cosmetic injectors do not agree with the new rules. Dozens of comments left on our social media post argued that not using terms, such as ‘anti-wrinkle injection’ and ‘dermal filler’ will further confuse (potential) patients and make it even more difficult to educate consumers. Many practitioners asked the question which terms they should use instead, frustrated at the difficulty to describe their treatments in copywriting aimed for their websites and social media.
The overall sentiment seemed to be a lack of understanding the motivation behind TGA’s decision. “Would love to know how this was tested and piloted to show with tangible evidence that it does in fact lead to better outcomes for patients,” Dr Jonathan Hopkirk wrote, while Jane Fielding, RN, argued that “Creative language is vague and confusing. […] Good conversations are often started from patients researching [their treatments] prior. Now they will be educated by sites from overseas.”
This thought was echoed by dermatologist Dr Cara McDonald, who wrote the following in one of her Instagram stories:
“Given the easy access to global information, I really wonder whether it is in the best interest for Australians to receive all the information they want on these drugs, brands and procedures from practitioners and influencers overseas rather than Australian professionals? The only thing we are doing is creating more confusion for the public who don’t understand why we (practitioners) all appear so ignorant and secretive about the things we do.”
Director of Perth-based aesthetic clinic Surskin, Jessica Wrightson, says the TGA’s decision doesn’t address the “core issues.” “If real change were to be encouraged, this would need to look at how medical doctors and clinicians approach every client consultation, taking a whole-person approach to their service,” she says, further elaborating that neglecting to “understand and offer them full fact solutions that they may not be aware of, this is where the faults lie.”
Arguments For Stricter Guidelines
However, there are also those who welcome the TGA’s decision, arguing the industry needs to take advertising medical treatments more seriously. Michael Fraser, Co-Founder of Operation Redress, says that the non-surgical and cosmetic injectables industry already has significant non-compliance with Ahpra’s and the TGA’s existing guidelines, and that most practitioner who argue they won’t be able to educate patients anymore, haven’t been doing so in a compliant way to begin with.
“A number of providers still advertise Haytox, promote the use of Botox and name the brand, despite TGA warnings and national media. Some are even bold enough to disclaim the prohibition of a term and then subsequently use it. This is extremely unfair to practitioners attempting to do the right thing,” Michael explains.
“The argument of educating patients through practitioner posts is problematic. Almost all posts promoting these procedures would not meet the standard required to educate other practitioners. The bulk is informational at best.”
Describing what he sees online every day, Michael urges practitioners to rethink the way they educate their patients. “Educational material does not use cinematic camera angles and movement paired with emotive music. It does not end with “xoxo Nurse [name]”. It does not comment on how beautiful a patient is. It does not ignore or downplay risks. It does not use slightly different lighting, framing and angles to misrepresent outcomes. It does not promise or assure confidence or safe outcomes. It does not present data as a fact and hide text at the bottom that says it is a generalisation. It does not leave out key information. It does not exclude source material. It is not dance videos or content with obscene language. It does not target children or use children in advertising. It does not use girl math or Barbie or tomorrow’s meme to promote procedures. It does not joke about prescription medication.”
Overall, there seems to be a lack of consensus when it comes to the ‘why’ behind Ahpra’s and TGA’s regulations. While many are trying to come up with terms they can use to describe their injectable treatments, making their messaging virtually the same as before by finding ‘loopholes’ to stay compliant, Michale argues that the point of all these regulations is “injectors should not be promoting prescription products as a solution to a perceived issue on a prospective patient they have never met.”
“The bulk of advertising is designed to drive sales. This is not a theory; practitioners post about their approach to drive sales. Industry events discuss KPI’s and speaking guests have encouraged practitioners to make more dancing videos. Safety is at risk when sales are the driver. Nobody is telling any provider that during a consult, they can’t educate their patients. That is actually their obligation,” he continues.
Is this the beginning of the end of advertising injectable treatments altogether?
“We don’t advocate for a total ban on advertising injectable treatments,” says Michael. “Our advocacy is around improving patient safety, which includes ensuring no person is convinced by a provider’s Instagram video or imagery into thinking they need to fix perfectly natural or normal variations in their body. Wrinkles are not a medical condition, but after viewing provider posts on social media, you could be mistaken for thinking it is.”
The delicate balance between running a successful business in aesthetics while holding up the highest moral standards, is a tricky one, and is not just limited to injectables. A large part of the beauty industry is built on people’s insecurities, but there is no doubt that many aesthetic services and treatments help people feel better. Navigating this relatively new industry continues to be difficult.
We are awaiting clarification from the TGA on these recent changes, which are due to be posted on their website later this month.
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