Nothing’s impossible! – Exploring pathways for privately practicing registered nurses in the cosmetic injectables industry

Ms Marina Buchanan-Grey1, Ms Jenny Kilworth1

1Department Of Health Tasmania, Hobart, Australia


In late 2020 professional practice issues for independent privately practicing registered nurses (PPRN) became apparent raising concerns of potential breaches of Tasmanian legislation and public safety. In parallel, the Fact Sheet ‘Legal supply of cosmetic injectables in Tasmania’ published on the Department of Health’s website caused concern for the cosmetic industry rather than provide clarity on the legal obligations regarding Prescription Only cosmetic injectables in Tasmania. Consequently, the industry sought clarification on nursing practice in the context of the legislation.

The Department engaged with the industry to consider ways of working, within the specialty context of cosmetic injectables. A forum was held in Hobart in May 2021 facilitated by the Office of the Chief Nurse and Midwife, to discuss professional practice issues for PPRNs in the cosmetic injectables environment. The forum explored current issues and considered enablers to ensure PPRNs could work within the current Tasmanian legislative frameworks, whilst strengthening the clinical governance model for their private practice.

A licensing model under the Health Services Establishment Act 2006 is currently being explored through the Department’s Regulation Licensing and Accreditation Unit enabling PPRNs providing cosmetic injectables a pathway to apply for authorisation under section 25A of the Poisons Act 1971, satisfying the legal requirements for possession of Schedule 4 medications within a licenced private health service facility.

Such approach addresses the professional practice issues highlighted, balancing safe, quality care for the community with the business needs of the cosmetic industry.  Safety and quality guidelines for Tasmanian PPRNs are also being explored.


Marina is Tasmania’s Deputy Chief Nurse and Midwifery Officer. Marina has worked in the UK and Australia across clinical and executive nursing roles providing strong leadership and engagement while improving quality outcomes.  Marina is a respected and trusted leader driven to provide excellence in health care.

As the ADoN for the Department’s Regulation, Licensing and Accreditation Unit, Jenny provides clinical input and advice for private health services and non-emergency patient transport and for the accreditation of Tasmanian health services.  Jenny’s role involves collaboration with key stakeholder to achieve regulation and legislative compliance underpinning the delivery of safe, high quality healthcare.