Who is qualified to inject fillers and wrinkle treatments?

Schedule 4 substances (for example, Botulinum toxin) are prescription only medicines. This is the ASPS official statement about their administration by nurses.


1. Introduction
Botulinum Toxin is commonly prescribed by doctors for the purpose of cosmetic treatments.
It may be lawfully administered by either the doctor, or a nurse acting under the supervision
and instruction of a doctor, and in accordance with a written order provided by the doctor.

2. The Role of Nurse Injectors
Adequately qualified and properly supervised nurse injectors can provide a valuable and
appropriate service to patients undergoing cosmetic treatments provided proper procedures
are in place to ensure the required standard of care is met.

Supervising doctors must be satisfied that the nurse has adequate qualifications, training and
expertise for the duties performed. Whilst it may be the nurse who administers the
Botulinum Toxin, the doctor remains responsible for ensuring the treatment is provided safely
and appropriately.

The doctor should be immediately contactable in order to respond to a nurse or patient’s
concern in a timely manner.

3. Regulatory Requirements for Schedule 4 Substances
Botulinum Toxin is a Schedule 4 substance. The precise legal requirements for the possession,
use, storage and disposal of Schedule 4 substances vary between States and Territories. It is
the responsibility of the prescribing doctors to be aware of the legal requirements in their
jurisdiction and ensure they are complied with.

4. Premises for Injection
Botulinum Toxin should only be administered in an appropriate setting with adequate
equipment and protocols in place. The premises must be properly equipped to deal with
anaesthetic toxicity effects and potentially life threatening anaphylactic reactions. The premises
must provide facilities and procedures for all healthcare workers to adhere to infection
control principles, including safe injection practices and aseptic technique for the preparation
and administration of all injectable medications.

5. Initial Consultation
The doctor’s initial consultation with a patient considering Botulinum Toxin treatment should
include a proper clinical history and examination, as well as a complete discussion of the
realistic potential benefits, side effects and possible complications.

The treating doctor should always be satisfied of the indication for the proposed treatment,
the patient’s medical suitability for Botulinum Toxin and that full and informed consent has
been obtained.

Remote consultations (i.e. via telephone or ‘Skype’) are not recommended, and may, in the
opinion of the Australian Society of Plastic Surgeons, unnecessarily hamper the doctor’s ability
to undertake a proper patient assessment.

6. Written Instruction for Administration
The doctor must provide written instructions for the administration of Botulinum Toxin for
the patient including directions on the dose, treatment frequency and area. These instructions
may remain valid for a period of up to 12 months. A nurse must never administer Botulinum
Toxin without a valid order from a doctor.

7. Review of Treatment Plan by Doctor
The patient and/or administration instructions should be reviewed by the doctor as necessary,
including if:
I. There is a material change in the patient’s general medical condition; or
II. The patient wishes to see the doctor for any reason whatsoever; or
III. The nurse is concerned or unclear about the written instructions for any reason; or
IV. An unexpected side effect, complication or result of treatment has occurred.
V. In such cases, the doctor should personally review the patient to determine whether
the treatment plan remains appropriate, and no further treatment should be given
until this review has taken place.

A recent NSW HCCC media release about a nurse suspended, by the NSW Civil and Administrative Tribunal, for professional misconduct for administering cosmetic injections without a prescription and without medical supervision. (12 June 2014) can be read below:

The Health Care Complaints Commission prosecuted Ms Rosalie Piper, a registered nurse before the NSW Civil & Administrative Tribunal.  The Commission alleged unsatisfactory professional conduct and professional misconduct regarding her conduct in providing Botox and other cosmetic injections to patients without a prescription and without appropriate medical supervision between 2009 and 2011.

The evidence established that  Ms Piper entered into an arrangement with a medical practitioner whereby the medical practitioner ordered supplies of Botox and dermal fillers which Ms Piper administered to patients at the medical practitioner’s surgery. Ms Piper also administered the injections to patients at a day spa.

Ms Piper admitted the conduct the subject of the complaint and that she was guilty of unsatisfactory professional conduct and professional misconduct


On 12 June 2014 the Tribunal’s decision was published. The Tribunal found unsatisfactory professional conduct and professional misconduct and imposed a reprimand, a three month suspension and conditions on Ms Piper’s registration.

Further Information

The full decision is available at Caselaw NSW

For further information, contact the Executive Officer of the Health Care Complaints Commission, on 9219 7444 or send an email to media@hccc.nsw.gov.au.

The information in this media release is correct at the time of publication. Orders may change; for example, conditions may no longer apply. For current information regarding the status of a registered health practitioner, including any conditions that currently apply, please check the National Register at www.ahpra.gov.au.


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