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Adapting to the Medicines and Poisons Act 2019: Overview for Queensland Clinics

The Australian beauty and aesthetic industry continues to evolve, with Queensland furthering the changes by implementing new regulations under the Medicines and Poisons Act 2019 (MPA) and the Medicines and Poisons (Medicines) Regulation 2021 (MPMR).

These changes bring a renewed focus on compliance, patient safety, and ethical practice for clinics offering cosmetic injectables.

At ABIC, we understand that adapting to these new requirements can be challenging, particularly for businesses used to previous regulatory frameworks.

The introduction of the new laws impacts many aspects of clinic operations, from prescribing and purchasing medicines to storage and infection control protocols.


What Do These Changes Mean for Clinics?

The key takeaway is that only medical practitioners and nurse practitioners working for the business can prescribe or purchase S4 medicines, such as Botox® or dermal fillers.

The elimination of standing orders and the introduction of stricter controls over who can administer and purchase medicines represent a significant shift in practice.

Telehealth providers are also prohibited from purchasing medicines for locations where they do not physically practise.

Storage requirements have also been updated, requiring clinics to appoint a medicines store establisher to oversee compliance in shared clinics.

Advertising S4 injectables remains strictly prohibited, reinforcing the need for ethical and compliant marketing.


How ABIC Can Help

At ABIC, we are here to support you through these changes.

We have created a simplified overview of the changes which seeks to provide clarity on compliance requirements for clinics, ensuring you can adapt with confidence, however we encourage you to reach out to Queensland Health or seek legal advice tailored to your specific situation.

We also want to hear from you. How are these changes affecting your practice? Your feedback is invaluable, helping us advocate effectively for the industry’s needs and ensuring that regulatory changes reflect the realities of clinic operations.

Remember, regulatory compliance is about more than just ticking boxes—it’s about ensuring that our industry continues to prioritise safety, professionalism, and trust. Together, we can navigate these changes and thrive in an evolving landscape.


Here is your simplified Guide:


Simplified Guide for Compliance with the Medicines and Poisons Act 2019 (Queensland)


1. Prescribing and Administering S4 Cosmetic Injectables

  • Only medical practitioners or nurse practitioners working for the business can prescribe S4 cosmetic injectables.
  • Prescribers must assess each individual patient to determine the therapeutic necessity of the medicine before issuing a prescription.
  • Prescriptions can be for dispensing (to be filled by a pharmacist and collected by the patient) or for administration (administered directly to the patient by an authorised person).
  • All prescriptions must comply with the Medicines and Poisons (Medicines) Regulation 2021 (MPMR), ensuring they meet all legal requirements for lawful prescriptions.


2. Standing Orders

  • Standing orders cannot be used for administering S4 cosmetic injectables in beauty clinics.
  • Standing orders are restricted to specific institutions, such as hospitals, aged care facilities, and prisons, and cannot be applied in cosmetic settings.


3. Buying S4 Cosmetic Injectables

  • Only medical practitioners or nurse practitioners working for the business are authorised to purchase S4 medicines for use in that business.
  • Registered nurses, enrolled nurses, admin staff, or any unauthorised individuals cannot place purchase orders, even if they are acting on behalf of a doctor or nurse practitioner.
  • The authorised buyer must complete the purchase order themselves. If using an electronic system, the buyer must use a unique identifier that cannot be shared with anyone else.
  • Medicines can only be delivered to the place of practice where the authorised buyer is physically present.
  • Telehealth practitioners cannot purchase or receive stock for locations where they do not physically practise.


4. Supplying S4 Cosmetic Injectables

  • Suppliers (e.g., wholesalers or pharmacists) can only supply S4 injectables to authorised buyers working for the business.
  • The supplier must ensure that the purchase order meets all legislative requirements under the MPMR before fulfilling the order.


5. Storage of S4 Medicines

  • In shared clinics, the person in charge must appoint a medicines store establisher in writing.
  • This person must be an authorised individual, such as a medical practitioner, nurse practitioner, or registered nurse.
  • If a sole practitioner operates the clinic, they are automatically the medicines store establisher.
  • Medicines must be stored securely in an area where they are inaccessible to the public and in line with manufacturer recommendations.
  • Medicines can only be removed from storage when they are intended to be administered to a patient.


6. Advertising of S4 Medicines

  • Advertising of S4 cosmetic injectables remains strictly prohibited under the Therapeutic Goods Administration (TGA) guidelines.


7. Telehealth Restrictions

  • Telehealth practitioners cannot purchase S4 medicines for locations where they do not physically practise.
  • This includes placing orders or arranging delivery for any location where they provide services remotely.


8. Buying and Administering S2 and S3 Medicines

  • Only authorised individuals that work for the business, such as medical practitioners, nurse practitioners, or registered nurses, can buy or administer S2 and S3 medicines, such as numbing creams containing lidocaine.


9. Infection Control Requirements

  • Clinics must comply with the Public Health (Infection Control for Personal Appearance Services) Act 2003 to minimise the risk of infection.
  • Healthcare facilities offering cosmetic injectables must also maintain an infection control management plan as per Chapter 4 of the Public Health Act 2005.


10. Further Information

  • Contact the Medicines Approvals and Regulation Unit (MARU) at [email protected] for specific queries.


Visit the Queensland Health website for detailed guidance and additional resources and see the official notice here > https://www.health.qld.gov.au/__data/assets/pdf_file/0038/1393994/fs-cosmetic-injectables.pdf


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