Speaking to the Herald about the bill, Dr. Culbard said: “Scotland’s decision to regulate non-surgical cosmetic procedures is more than a legislative milestone – it is a vital step in protecting the public from harm.”
The Scottish Government’s Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Bill was published on the Scottish Parliament’s website on Wednesday.
The bill seeks to regulate beauty and wellness procedures, from Botox injections and dermal fillers to higher-risk treatments like Brazilian Butt Lifts and Thread Lifts.
At present, anyone can carry out non-surgical procedures such as Botox, dermal fillers and skin rejuvenation without formal training in Scotland.
The proposals require licensed practitioners to administer certain non-surgical cosmetic treatments in controlled settings that can meet safety and hygiene standards.
Under the proposals, procedures involving botox and dermal fillers can still be carried out by non-medical professionals, but must be “supervised” by a qualified healthcare professional in an environment regulated by Healthcare Improvement Scotland (HIS).
However, the clinician said the plans need to provide more clarity on how supervision and physician standards are defined.
“Oversight in name only will not protect the public,” said Dr. Culbard, “Patients need substantive oversight – just as there already is for dentists and other health professionals.”
Ministers told the Herald that the oversight requirements will be introduced once they consider the impact of the UK Internal Market Act, as they need to ensure that any new licensing or oversight rules for cosmetic procedures comply with UK-wide market access principles.
Scotland can only impose stricter standards if they can be justified as necessary to protect public safety
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If passed, the legislation would also create new offenses for providing non-surgical procedures outside of premises where qualified health professionals are available or to people under 18.
It will also give Healthcare Improvement Scotland new powers to enter and search premises where these procedures are suspected to be being carried out in breach of these offences.
The Scottish Government’s introduced bill was largely welcomed by medical professionals, however, some said the measures needed to go further.
The British Association of Aesthetic Plastic Surgeons has previously said the regulations are a “big step” forward, however, it would like more restrictions to apply to those administering Botox and other injectables in Scotland.
A Scottish Government spokesman said: “This Bill will protect public safety by ensuring that procedures are carried out in the right place, in an environment where suitable health professionals are available.
“The legislation gives the power to set supervisory requirements. This will be done once we have further considered the impact of the UK Internal Market Act (2020).”
The government’s plans also allow for stricter measures to be imposed on procedures such as breast and buttock augmentation, which will only be allowed to be carried out by a qualified health professional in an HIS-regulated environment.
The changes are expected to have an immediate impact on dentists, some of whom already offer cosmetic facial treatments as part of their clinical practice.
Dentists are trained in anatomy, infection control and complication management and are already regulated by the General Dental Council – giving them a clear professional framework which Dr Culbard says should set the standard across the wider cosmetic industry.
“Dentists and medically trained clinicians are able to do these procedures safely,” he said. “We already work to strict clinical and ethical standards. What is needed now is for the entire field to be held to the same level of accountability.”
The clinician said plans should include a treatment plan and comprehensive medical history checks as well as careful, consistent aftercare and long-term follow-up to ensure each patient is supported and cared for beyond initial treatment.
She added: “It’s not about rejecting face enhancement – it’s about committing to doing it the right way.”
“Dentists and medically trained clinicians are able to do these procedures safely,” he said. “We already work to strict clinical and ethical standards. What is needed now is for the entire field to be held to the same level of accountability.”
Dr Culbard, who has a special interest in minimally invasive dental and facial cosmetic treatments, said the regulation was long overdue amid increasing reports of patients suffering damage from unqualified doctors.
“Too often, these procedures are carried out by people without medical qualifications, operating without even basic clinical safeguards,” he said. “As a clinician, I’ve seen the damage that poor treatment can cause — from scarring and infection to vision problems and even blindness.”
Dr. Culbard also highlighted the increasing use of advanced technologies — such as ultrasound imaging and medical-grade lasers — that can improve the safety of treatment, but only when used by trained professionals.
“Technology means nothing without proper regulation,” he said. “Used irresponsibly, it can cause harm; used correctly, it can transform lives.”
For Dr Culbard, the bill represents an opportunity not only to curb unsafe practices, but to raise standards across the board.
“Ultimately, it’s about more than aesthetics,” he said. “It is, above all, about public safety. Let’s use this bill not just to fix what’s broken, but to raise the standard of care for everyone.”
In the Scottish Parliament, opposition parties criticized the SNP for being slow to act and called for stricter safeguards on non-cosmetic treatments.
The Scottish Greens have also called for only medically trained professionals to carry out these procedures.
The Bill follows a consultation carried out in 2020 which found that 98% of respondents supported the principle of further regulation of procedures led by those who are not qualified health professionals.
Public Health and Women’s Health Minister Jenny Minto said: “Our aim is to ensure that strong and proportionate legislation is in place so that anyone who chooses to have these procedures can do so safely.
“We have worked with a range of stakeholders including business owners, health professionals, non-health professionals, environmental health practitioners and regulatory professionals to develop our proposals.
“Our priority is to address the public safety concerns that exist in this area, while ensuring that businesses that may be affected have access to support.”
