Dr Christopher Leat on new rules rocking the cosmetic injectables industry

A leading Gold Coast cosmetic physician has weighed in on the new rules rocking the multimillion-dollar cosmetic injectables industry – and the incredible impact of the rise and rise of Botox.

It may not show on their wrinkle-free faces, but operators within the Gold Coast’s multimillion-dollar cosmetic injectables industry are extremely worried.

New national guidelines on non-invasive procedures like Botox and fillers have rattled practitioners, with the Australian Health Practitioner Regulation Agency cracking down on ‘batching’ and boosting training as it moves to tighten oversight of the $4.1 billion sector.

But for Benowa cosmetic physician Dr Christopher Leat, it’s basically business as usual.

After 30 years in the industry as founder and director of Envisage Cosmetic Clinic, Dr Leat said while the changes, which will be enforced from September, might mean additional paperwork, his practice was otherwise compliant.

However, he said many in the industry were alarmed by the reforms, particularly with Queensland practitioners subject to even stricter rules.

The AHPRA guidelines stem from a 2023 review after widespread reports about unsafe practices, including the predatory targeting of under-18s, inadequate training for practitioners, and poor screening of patients, including 52-second telehealth consultations.

Benowa cosmetic physician Dr Christopher Leat,

The new rules specifically target batch prescribing – where prescriptions are issued for multiple patients – with only suitably trained practitioners to prescribe Schedule 4 drugs like Botox following an in-person or video consultation.

That prescribing practitioner will now be responsible for the patient, regardless of whether they performed the procedure, with the patient to be given explicit, written information about the prescriber, the practitioner, product details and after-care.

The guidelines also include stricter controls on advertising, including a ban on testimonials from social media influencers, and increased minimum training and experience levels for practitioners.

However, the regulations go even further in Queensland, with either a doctor, or nurse practitioner with prescribing rights and additional qualifications, required onsite, or alternatively only storing individually dispensed injectable medications.

Dr Leat said while the changes were certainly causing disruption, they were also necessary.

He said the Non-Surgical Symposium being held at the Gold Coast Convention and Exhibition Centre this weekend was directly addressing the industry’s anxiety, dedicating the bulk of its Sunday schedule to the issue.

“They’ve devoted the whole of Sunday morning to these regulations. We have people from Therapeutic Goods Australia, AHPRA, one of the large medical insurance companies and a whole panel discussion on this,” said Dr Leat, who was also a speaker at the conference.

“People in the industry are still not 100 per cent certain of all of the details and exactly how it will be applied.

“I think everyone would agree that you need to have more regulation in the industry, or at least more enforcement for the regulations, as well as some clarity around it.

“There are plenty of good practitioners but there are ones that are not as careful. I have seen patients who have been inappropriately treated, not a huge number, but it does happen.

“Every treatment has potential for side effects and most are minor but with something like dermal fillers, it’s rare but the risks are potentially serious.”

Lisa Oakman a registered nurse at The Glow Co. Aesthetics, with Megan McRae a registered nurse at Attuned Aesthetics, attend a protest outside Parliament House in Brisbane last Tuesday. Picture: Steve Pohlner.

AHPRA’s cosmetic surgery hotline received 1282 calls from patients and doctors and 472 formal complaints or notifications about cosmetic procedures since it was established in September 2022, with cases including permanent irreversible facial nerve damage as well as potentially life-threatening strokes from cosmetic injectables.

Dr Leat said he was relieved that the changes aimed to put safety before sales, with practitioners required to confirm the patient’s expectations were realistic, must discuss risks and alternatives – including no treatment, be transparent about their own skills and experience, and explain all costs.

They must also assess patients for underlying conditions, such as body dysmorphic disorder.

However, the Queensland Aesthetic Nurses United, a collective of cosmetic nurses advocating for safer, fairer regulation of the industry, held a rally at Parliament House in Brisbane last Tuesday to object to the Queensland Health requirement that a doctor or nurse practitioner was required onsite.

Industry experts estimate that 80 to 90 per cent of injectable clinics are run by nurses who arrange telehealth consults for their patients, where doctors remotely prescribe the products and clinics hold supplies of prescription fillers and injections onsite, which would be illegal under the changes.

Many of these clinics use a ‘scripting’ service, which has become big business, where nurses pay a membership fee to access telehealth doctors.

A brow lift procedure is performed on a young female client while using Botox fillers. Picture: iStock.

QANU has warned the injectables crackdown enforced by the Queensland Government could lead to higher prices and patients risking products from a “black market”.

However, Dr Leat said he believed the changes were aimed at targeting ‘scripters’, rather than the nurses themselves.

“People are saying these regulations are sexist because it’s penalising nurses who are trying to get ahead by setting up their own clinics, but what it’s really trying to do is make it harder for bulk suppliers to continue to operate in the way they have,” said Dr Leat.

“If a significant side effect occurs, the patient needs to be appropriately and quickly treated. If you have a nurse without a lot of experience and a doctor based interstate, that’s where patients could fall through the cracks.

“With such a large number of cosmetic practitioners, there is also a financial pressure or incentive on some of them to perform treatments – if they don’t, they don’t get paid.

“There needs to be more oversight and these regulations are trying to instil a balancing act. It’s providing more protection and care for the consumer, we just have to figure out how to help people to comply.

“At Envisage, I’ve actually got a clinic policy document that we follow which says the patient comes first. You do what’s right for the patient, not for your books.

“There have been plenty of times I’ve advised people not to go ahead with treatment. They normally thank me and say no one else has been willing to tell them the truth.”

Dr Leat said the Gold Coast had long been a capital for cosmetic work, but said that competition could lead to some unethical practices.

He said he was relieved to see guidelines on advertising after witnessing some unethical messaging.

“I’ve seen before and after pictures that are radically different in terms of lighting and pose, which is not giving a true picture,” he said.

“Even worse, I’ve seen AI used for the ‘after’ photo … that’s highly unethical and totally inappropriate.”

While Dr Leat might have founded one of the earliest cosmetic practices in this city, he said he never realised how big the industry would become.

However, he said while its popularity grew, he was glad to see trends turn back towards a more natural look.

“I was at a conference in Adelaide in the mid-90s and an American doctor came out and told us about Botox,” he said.

“I thought, well, I could see some people using it … but not many. How wrong can you be?

“We’ve come a long way over 30 years, attitudes have really changed. There is much less secrecy around getting treatments, we even see a lot of men these days.

“One of the newer trends now is a real focus on skin quality and having a natural but healthy look.

“I really hope we keep heading that way. The over 30s and 40s have always wanted their work to look natural, but now the younger patients are asking for the same.

“It’s a relief because everybody was starting to look the same.

“Besides, so often you see the before and after pictures and think she was prettier before. You’ve just given her great whopping lips that don’t fit.”

Originally published as Dr Christopher Leat on new rules rocking the cosmetic injectables industry