Warning for Qld doctors after clarification on cosmetic injectables

Queensland Health recently revised its guidance on cosmetic injectables. This clarifies that registered nurses cannot buy stock of botulinum toxin and dermal fillers (both Schedule 4 medicines) for use at a beauty treatment/cosmetic business. Injectables must be bought by a doctor or nurse practitioner, who cannot supply stock for use at cosmetic injectable clinics where they will not have exclusive custody and control over the stock. This has led to many nurse-led cosmetic clinics realising they are operating in breach of the legislative requirements in Queensland.

In response, some clinics have approached doctors to assist nurse-led clinics as locum prescribers. Approaches have been made to very junior doctors, with enticing and lucrative offers. Also, doctors who own premises have been asked to take on cosmetic nurse businesses into their location and act as the purchaser and prescriber.

Members holding policies with MDA National in Post Graduate and Doctors in Specialist Training categories are only covered (indemnified under the terms and conditions of their MDA National professional indemnity insurance policy*) for cosmetic procedures where the procedures form a part of their training program and are supervised by a suitably qualified and indemnified doctor. Only the procedures listed under the Minor Cosmetics category are covered. Adequate training must have been undertaken specific to the cosmetic procedures being performed or prescribed. Any cosmetic practice outside of their training program or undertaken via telehealth is not covered.

MDA National advises any doctors approached about an arrangement such as this to carefully consider and manage the risks involved, and comply with:

• Medical Board of Australia Guidelines for registered medical practitioners who perform cosmetic surgery and procedures
• Queensland Health Medicines in beauty treatment/ cosmetic businesses
• Queensland Medicines and Poisons Act 2019 (Qld) (MPA) and the Medicines and Poisons (Medicines) Regulation 2021 (Qld) (MPMR).
• Queensland Health Infection control management plans
• TGA Referring to cosmetic injectables in advertising
• indemnity requirements and obligations as per their professional indemnity insurance policy.

*2025/2026

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This blog contains general information only. We recommend you contact your medical defence organisation or insurer when you require specific advice in relation to medico-legal matters. The MDA National Group is made up of MDA National Limited ABN 67 055 801 771 and MDA National Insurance Pty Ltd ABN 56 058 271 417 AFS Licence No. 238073.