ARPANSA Consultation Regulatory Impact Statement: IPL & Lasers for Cosmetic or Beauty Therapy

Laser Safety Australia has made the following comments & recommendations to ARPANSA regarding their recent consultation:

1. National standards should be developed by ARPANSA of for 1) client care, 2) clinician education and training and 3) the accreditation of premises providing cosmetic/aesthetic services (Medical Board of Australia, 2015; Australasian College of Cosmetic Surgery, 2015)
2. Licensing of operators should be done by Radiation Health Departments in each state and territory according to their profession as per Table One over the page
3. LSA support mandatory minimum qualifications for all operators providing cosmetic/aesthetic services that use laser and IPL (Baumler, 2011; Edwards & Sams, 2010). We have outlined minimum qualifications in Table One over the page. We believe that best practice is initial training and then three yearly refresher training in laser safety.
4. LSA supports Option 1, a national consumer education campaign but not as a standalone solution
5. LSA does not support any of the other three licensing options as they are presented (Status quo or Options 2 or 3) as there is insufficient statistically significant evidence presented to substantiate them particularly the reduction in scope of practice for non-registered providers and nurses
6. LSA does not support a mandatory number of hours for any specific treatment by registered health practitioners and believe this is in contravention of current best practice (O’Connell, 2014). Laser Safety Australia’s position on practical experience for nurses and doctors is that once an accredited laser and IPL safety course has been completed that they then work within their scope of practice, identify a more experienced clinical mentor to assist in skill development, have standard operating policy and procedures in place, liaise with the manufacturer of the specific machinery that they will be using and begin to record practical experience in a log book. Once they are competent and this is corroborated by their mentor they are able to perform treatments. (AHPRA, 2015a)
7. We recommend that the capacity of the Australian Health Practitioner Regulation Agency (AHPRA, 2015b) and administrators of the Public Health Regulation 2012 (NSW Government, 2012) be examined with regards to complaints about registered and non-registered health practitioners who use lasers and/or IPL in health care.
8. LSA recommends that the Therapeutic Goods Administration approve all light-based, radiofrequency, ultrasound or other devices imported for skin health therapies
9. The use of lasers in surgery and podiatry also be examined to determine safety and equity in health care

Table One: Operator licensing

* Refer to FAQ Frequently asked questions: Online laser & intense pulsed light (IPL) aesthetic courses attached.