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If you walk around the city, you’ll find them in abundance: cosmetic clinics, sometimes more than one to a city block, advertising treatments like filler and Botox.
On Instagram and TikTok, you’ll see posts with hundreds of likes:
“If you’re in your 30s and wanna try botox in Toronto, dm me.”
“This is your sign to start botox.”
“Up to 50% off dermal filler.”
With the popularity of non-surgical cosmetic treatments on the rise, the College of Nurses of Ontario (CNO) released new guidance in July clarifying what responsibilities medical professionals like doctors, nurse practitioners and nurses have when it comes to treatment. Those changes also issue guidance on training, advertising and product and equipment use.
But while the guidelines were largely welcomed by medical professionals, a set of additional proposed changes that just wrapped public consultation are being met with mixed reactions, with some nurses arguing they could limit their ability to practice medical esthetics independently.
The July guidelines were a “welcome advancement” and are a first-of-its-kind for the field, said Dr. Jennfier Pearlman, physician and CEO of Pearl MD Rejuvenation, a medical esthetics clinic in Toronto.
But, the additional changes, if enacted, “will alter a lot of business models,” she said.
What are the proposed changes?
According to the CNO guidelines, nurses can administer treatments like Botox and filler, but they must get authorization from a doctor or nurse practitioner first.
The proposed change drawing worry from some nurses has to do with how that authorization gets issued.
Botox can be booked for the next day but you could be waiting months to get a potentially cancerous mole checked out. Public health-care advocates are worried that this shift toward out-of-pocket cosmetic care is a symptom of creeping privatization.
The CNO guidelines say nurses get authorized to perform non-surgical cosmetic procedures either through a directive or a direct order issued by a doctor or nurse practitioner.
A directive can apply to multiple clients, while a direct order requires the physician or nurse practitioner to give patient-specific instructions. The CNO is considering making direct orders a requirement for nurses to do medical esthetic treatments.
That means a doctor or nurse practitioner would need to consult each patient that comes in for every visit, even if it’s a follow-up, said Tracey Hotta, a registered nurse who runs a medical esthetics training company.
“I think it’ll be a lot of administration put in on both sides,” she said. “On the nursing side and also the authorized prescriber side … that is not necessary.”

Nursing association in favour of changes
While Hotta said the July-issued CNO guidelines “are great,” she is one of over 2,000 signatories to an online petition calling for the proposed additional changes to not be considered.
“I don’t think it would make a difference with patient safety,” she said.
The online petition states that the changes would “fundamentally change how esthetic medicine is delivered in Ontario,” because nurses may no longer be able to independently carry out follow-up, routine treatments. It also argues there is no clear evidence the changes would improve patient safety.
Kristi Green, spokesperson for the CNO, said the college believes the changes “will support client safety, clarify nurses’ accountabilities, and promote consistency across all areas of nursing.”
In addition to the medical esthetics changes, the college is also looking into changes across all practice settings, including clarifying delegation requirements for nurses, according to its website.
Esthetic medicine like Botox and microneedling might be more familiar to Canadians these days, but the industry’s growth could be outpacing safety. Medical esthetics are overseen by a variety of regulatory bodies across Canada, but as CBC’s Jo Horwood reports, some in the industry call it an ineffective framework that could lead to patient harm.
Pearlman said the change could alter a lot of current business models that have grown to rely on medical directives authorizing treatment remotely. But, those models could also “jeopardize” patient safety, especially as social media makes esthetic treatments seem lower risk, she said.
Doris Grinspun, CEO of the Registered Nurses Association of Ontario, said the changes would ensure quality control on issues like infection.
“We are less concerned about affecting the business as we are on the side of the college in terms of needing to regulate these procedures,” she said.
Public consultations on the changes wrapped Wednesday night. The CNO will decide whether to approve them in September.



