The Therapeutic Good Administration (TGA) is the Australian Government’s regulatory Agency for medicine and therapeutics. Working as a part of the Department of Health and Aged Care, the TGA is responsible for regulating the quality, supply and advertising of all medicines, pathology devices, medical devices and most therapeutic treatments provided by qualified professionals in the field. The TGA’s main goal is to ensure that Australians who take any medicine or seek any treatment, including cosmetic injectables, remain safe and healthy.
The TGA updates their guidelines on a regular basis. However, in more recent times, there has been a crackdown specifically on how their treatments (or any clinic’s treatments for that matter) are being advertised online. After months of uncertainty regarding what can and cannot be shared, the TGA released the following statement in March of this year, explaining that:
“To resolve any inconsistency in interpretation across industry areas, the TGA no longer permits references to terms such as ‘wrinkle reducing injections’ where those terms would result in a reasonable consumer understanding the intention of the content is to promote the use or supply of a prescription medicine.”
The TGA continued, noting that these updates are in the best interest of Australians who are influenced by social media in this day and age:
“The update aligns with the focus of other regulators on health professionals performing non-surgical cosmetic procedures and acknowledges the increasing vulnerability of Australians influenced by advertising in the cosmetic space. Prescription only medications carry higher risks than goods available for self-selection. Decisions about treatments that involve the use of prescription medicines should only be made by a health professional in consultation with each individual patient.”
These guidelines have received quite a bit of backlash in the media from people in the cosmetics industry for a number of different reasons. The main concern is that that the industry feels it has been silenced, meaning they cannot properly educate people in Australia who want these cosmetic services.
While the TGA has put these guidelines in place to protect Australia, many cosmetic nurses and medical professionals fear that they might actually be doing more harm than good.
April Dunn, owner of PlatinumByApril (PBA) located here in Canberra and Queanbeyan, is a registered nurse who turned her focus to cosmetic injectables and tattooing due to her passion for helping patients feel more confident in their own skin. Being the founder and head nurse of the clinic, April, among many other duties, is responsible for staying up-to-date with any new rules, regulations or guidelines released by the TGA. This is critical to ensure her business is meeting the high standards of the Australian Government and providing a safe environment for her clients seeking any type of cosmetic treatment.
I had the opportunity to sit down with April to get a better understand of the issue and hear her opinions and concerns firsthand. Here is what she had to say in our recent Q&A interview:
Q: Before getting into how this impacts your business, could you please share a brief overview of what the TGA is and what their relationship is to the business?
A: So TGA stands for Therapeutic Goods Administration and it’s mainly there to regulate companies, advertisement, medications, poisoning and supplies as well. But there is TGA, and there’s also AHPRA (Australian Health Practitioner Regulation Agency) guidelines. At the moment TGA wants one thing and AHPRA wants another and they’re not lining up.
Q: There is obviously a relationship between these agencies and administrations and businesses such as yours, how do they communicate with clinics and practices?
A: There is pretty much a board, which is the TGA, which updates online ongoing TGA changes and it’s pretty much a legal requirement that if you’re not following the TGA, you can get fined or lose your registration and they monitor it. The main reason it’s there is to keep clients and patients safe.
Q: Most recently, what are the changes to the guidelines that directly impact your business and how do they affect PBA most?
A: They’ve recently put a massive hold on advertisement with any S4 medications, which is pretty much anti-wrinkle and derma filler. So they first said that we can’t use brand names, such as ‘Dysport’, ‘Xeomin’, and now they’re saying we can’t even use terms such as ‘anti-wrinkle’ or ‘derma filler’. We also can’t put before and after photos online. So that the main changes they’ve implemented. We also can’t talk about prices, we can’t have this on our website or on any advertising platforms. Because it’s an S4 medication and it needs to be prescribed by a medical professional, then they’re saying it shouldn’t be advertised because it’s a medical product.
Q: Why is it that the TGA feels the need to implement guidelines such as these ones?
A: I think that they think that this is going to benefit patients’ safety, but if you look at AHPRA, they are more saying that we need to make sure that we are educating our clients. But with the new TGA rules it’s stopping us from educating our clients and letting our clients know what medications we’re using and what each treatment is. I think if anything, it’s taken a step back and confusing clients, it’s confusing patients and I think people are going to start coming in wanting certain things but they’re not understanding what they’re booking in for. So, I think they’re actually doing themselves a disservice to our patients and our clients because we’re not able to educate them like we were able to.
Q: How often are these guidelines updated and how quickly do you have to adapt to them?
A: It definitely changes each time [the TGA boards meets]. I wouldn’t say they’re clear on that either. There are constantly new meetings, and they send out warnings. So, if they see you’re not following their guidelines, or if someone reports you, there’s been a lot of injectable nurses seeing each other as a threat and reporting them and then TGA will contact you and say ‘Hey, you’ve been reported and need to correct this, this and this…’. There is a cooling off period, then they issue warnings and fines. I know nurses have been fined thousands of dollars for not following these guidelines.
Q: How important is social media and advertising to your business?
A: I would say it’s definitely important, especially social media in this day and age. However, for business who have just started in the last year or two, I think it’s going to impact them massively. But people with an established business, who have their clientele are going to be fine. You can advertise as much as you want, but [ultimately] it’s about the service once you come into a clinic and making the whole experience so positive. How you get clients isn’t all about advertising, it’s doing good service and word or mouth. It’s going to be okay for people who are already in the industry, but people who have just started, I think it’s going to really affect them.
Q: Going back to when you first started your business, was social media a big form of advertisement for you then?
A: Yes. That’s where I would’ve gotten all of my clientele. It would be from Instagram and Facebook.
Q: What strategies do you have to implement moving forward to ensure your business continues to succeed despite the newest challenges? Does this also affect new treatments you begin to offer?
A: We already have such good procedure and policies, but I think it’ll be going over them. Mainly going over consultations, making them spot on. Just making sure the consultations are well structure, that they are consistent with every nurse in the clinic, and just acing what already happening in the clinic rather than focusing on advertising, ect…
With new treatments, that going to be hard. Because we already have such a good, loyal clientele, when they come in, they ask me. When they come in, we’re allowed to give an in-person, face to face consultation so I think it should be fine.
Q: Do you really think these new TGA guidelines are going to keep people safe as they intend to?
A: This is one that a lot of people have been talking about at the moment. I think it’s actually going to do the opposite. I think they’re [clients] going to get confused and you can’t educate clients on what procedures are. I know that they can come in for a consultation, but most people do their research online before they come into a clinic to do their consultation. If anything, there has been a lot of people speaking on that people won’t know what treatments are out there, people won’t know prices and they’ll probably venture out to other countries. They’ll go to these countries because they are allowed to say what they [treatments] are, say the prices, and talk about it on social media and thing could go wrong and it’s different over there, and we’ll have to deal with them after. I actually think it’s going to impact the industry negatively. I think we need to look more into certification, training and make sure all of that is being monitored, because it’s not monitored in the industry at the moment. That’s what they need to focus on, the actual training and certifications [of injectable nurses], not advertising. I think they’re focusing on the wrong things.