Botox and dermal fillers are the most common names that come to mind when one mentions injectables, but there are many other cosmetic concoctions that companies have been peddling to be administered via injections. These include mesotherapy (injecting a cocktail of vitamins, plant extracts and other substances in the middle or meso layer of the skin), PRP (Plate-rich plasma or vampire facial popularised by Kim Kardashian), and hyaluronic acid skin boosters.
But as per the recent notice by The Central Drugs Standard Control Organisation (CDSCO), no cosmetics will be permitted for use as injections and are only intended to be rubbed, poured, sprinkled or sprayed. Injectable cosmetic procedures such as Botox or fillers can only be administered by licensed medical doctors with the right training and qualifications.
Gurugram-based Dr Geeta Grewal, a trained surgeon, cosmetologist and founder of 9 Muses Wellness Centre says this move was long coming. “Patient safety concern has been an issue as complications related to injectables have been rampant. There are many cases in the consumer court too. This decision has been necessary because of the number of complaints. But as demand rises, patients are getting more aware that this is a skill not possessed by every aesthetician,” she says.
Injectable aesthetic procedures were never intended to be performed by non-medical professionals, says Dr Chytra V Anand, cosmetic dermatologist and founder of Bengaluru’s Kosmoderma Clinics and SkinQ. From a patient safety perspective, this distinction is critical.
The minimum legal requirement for performing aesthetic injectables in India is that the practitioner must be a Registered Medical Practitioner (RMP). “However, being an RMP alone is not sufficient. Since aesthetic medicine is a relatively new and rapidly evolving , injectable aesthetic procedures are not comprehensively covered in the undergraduate medical curriculum. Therefore, doctors performing these procedures should undergo additional structured training in aesthetic injectables and complication management to ensure they have the necessary knowledge, technical skills and clinical judgement,” notes Dr Anand. Dr Grewal reveals that many clinics hire Unani or Ayurvedic professionals or physiotherapists to inject. “I get many applications from physiotherapists too. Another application I recently received was a BA graduate who later decided to do a fellowship from Dubai in aesthetics—people with vague qualifications have been trickling into the aesthetic industry because of the hype. The industry needs to be regulated as people are just getting into the field without any interest in it,” rues Dr Grewal. She has seen severe cases where patients who went to non licensed clinics suffered from skin burns, arterial blocks and necrosis of the skin. And these complications require immediate and appropriate medical management.
The diversification of products and their labelling in India needed more clarity, says Dr Anand. “Any product intended to be administered by injection should be appropriately evaluated and registered under the applicable regulatory pathway. These products undergo significantly more stringent assessments for quality, sterility, manufacturing standards, safety and clinical performance than products intended solely for external cosmetic use,” says Dr Anand.
With the change in the directive, medical representatives visiting her clinic have stopped promoting mesotherapy, PDRN as injectables, says Dr Grewal. “Earlier, they would promote a product as an injectable. Now they are specifying that it’s a non-injectable product. So the implication of the law is coming tighter on the companies selling these formulas too. They can’t promote a non-injectable drug as an injectable and earn more out of it,” says Dr Grewal.
Dr Anand flags this too, she saw a rise in injectable products being marketed or registered as cosmetics despite being administered by injection. This created ambiguity regarding their regulatory status and facilitated their use in both medical and non-medical settings outside the intended regulatory framework. “The CDSCO notification helps clarify that products administered by injection cannot be treated as cosmetics simply because they are used for aesthetic purposes,” states Dr Anand.
For those currently pursuing courses in aesthetics, you need to be interested in them, says Dr Grewal as giving results is not as easy as it looks in an Instagram before-after Reel. You need an in depth understanding of the anatomy because these procedures are blind procedures. “When a surgeon cuts open the body you can see the tissue, with injections you don’t. If you don’t know the depth and the feel of the tissue on the injection’s needle, which tells the surgeon whether you’re in a safe or an unsafe place, or if the product is going in the right or a wrong place, I really don’t know how these people are allowed to work. This move stops all the malpractice, hopefully,” says Dr Grewal.
With so many in-clinic treatments available today, non-medical aestheticians and beauticians continue to have an important role within aesthetic practice, says Dr Anand, and they don’t just have to rely on filler and Botox appointments. “They can assist medical practitioners, provide patient education, perform non-invasive aesthetic procedures that fall within their scope of practice and contribute significantly to patient care. However, injectable procedures should remain exclusively within the domain of appropriately trained RMPs, be it aesthetic Doctors dermatologists or plastic surgeons ensuring accountability and clinical care.”
Dhara Vora Sabhnani is a Mumbai-based writer.