New statement aims to clarify Council’s position on safe use of botulinum toxin
Doctors must not let inexperienced nurses give Botox to patients, the Medical Council has said, adding that the senior physician remains accountable for all treatment outcomes, even when the treatment is administered by a colleague.
In a new statement highlighting doctors’ professional and legal responsibilities when prescribing and administering botulinum toxin, the Medical Council also said that doctors are responsible that any such treatment meets accepted standards of practice.
Under Irish law, Botox treatment can only be given by a registered doctor of dentist, of others, such as a registered nurse, who are acting ‘in accordance with the directions” of a doctor or dentist.
“While the phrase ‘in accordance with the directions’ is not explicit, the Medical Council advises that doctors must not delegate the administration of botulinum toxin to a registered nurse unless they are satisfied that the nurse has the necessary knowledge, skills and competence,” said the Council’s statement.
“A doctor may only delegate a task or activity in which they themselves are familiar, competent and appropriately trained. The doctor retains professional responsibility and accountability for the outcome.”
The statement comes after aesthetic medicine experts raised concerns around the unregulated use of Botox and other cosmetic treatments in Ireland.
In a 2023 letter the group of 30 doctors led by President of the Irish Faculty of the British College of Aesthetic Medicine (BCAM), Dr Eithne Brenner, expressed worries around the increase in non-medically trained persons, including hairdressers and make-up artists, attending one-day courses and then setting up as administrators of Botox and other cosmetic treatments.
“These individuals are utilising highly sinister social media strategies to prey on vulnerable members of the public. They offer high-risk cosmetic medical procedures at bargain prices, often in unsanitary and unregulated premises.”
An RTE investigation last year also exposed how some non-medically licenced members of the beauty industry have been administering Botox to their clients.
The programme also showed how these treatments were being supplied wholesale across the border to members of the public to be sold on to individuals, without having the licence required to sell these medicinal products.
“It is important to remember that the sale, supply, or administration of botulinum toxin by unqualified or unregistered individuals is illegal, unsafe, and unacceptable,” said the Medical Council’s head of regulatory policy Fiona McVeigh.
“Patients receiving these treatments outside regulated clinical environments face unnecessary and preventable risks.
“As well as referring to our guidance, we strongly recommend that patients and members of the public check the Medical Council’s register to ensure their doctor is registered.”
Medical Council CEO Dr Maria O’Kane emphasised that all medicines containing botulinum toxin are prescription-only.
“Under EU law, doctors established in other EU countries may lawfully prescribe certain medicines, such as botulinum toxin, to patients in Ireland,” she said.
“However, under Irish law, only registered doctors, registered dentists, or registered nurses acting in accordance with the directions of a doctor or dentist, are permitted to administer Botox in Ireland.”
“Patient safety is paramount, and doctors must not delegate the administration of Botox to a registered nurse unless they are satisfied that the nurse has the necessary knowledge, skills and competence. The Medical Council actively works with its stakeholders, including the Dental Council, HPRA and NMBI on a collaborative approach to key issues to ensure patient safety remains a priority.”
The Medical Council said that its statement on Botox ‘serves as a foundation’ for the responsible use of the treatment in clinical practice. It should be read in conjunction with the Guide to Professional Conduct and Ethics for Registered Medical Practitioners (9th Edition, 2024) and considered in conjunction with other professional regulatory guidance and law.
