RTE Radio 1 Morning Ireland 23/7/25 with Aisling Kenny

The debate over Botox administration between nurses and doctors in Ireland centers on whether nurses can administer Botox without a doctor present, with doctors advocating for strict supervision while nurses argue they are adequately trained. Dr. Sean Fitzpatrick, president of the Irish College of Aesthetic Medicine, emphasized patient safety concerns, while Dr. Lisa Cunningham highlighted that nurses already administer prescription medications daily in various healthcare settings without immediate doctor supervision. The regulatory bodies, including the Health Products Regulatory Authority and the Nursing and Midwifery Board of Ireland, are working to provide clarity on the matter, as the current legislation is open to interpretation.

Dr Sean Fitzpatrick: “When you open any box of Botox, and it states very clearly, Botox  (Bocouture, which is a type of botox) may only be administered by doctors with appropriate specialist knowledge. Black and white.”

Botox is a billion dollar industry across the world. Now at the centre of a heated debate here between nurses and doctors. Dr. Sean Fitzpatrick, president of the Irish College of Aesthetic Medicine, says, nurses should only be allowed to administer Botox when a doctor is present in a clinic.

Dr Sean Fitzpatrick: “In a situation where you have the administration of a prescription medication. If something goes wrong, whether it's an anaphylaxis, an infection, it requires a prescription medication. It requires immediate intervention by a doctor. If the doctor is not in house. That is a patient safety issue”.

Under the law, Botox must be prescribed and administered by a doctor or dentist. The law states that a doctor or dentist may direct a registered nurse to administer a prescription medicine to a patient, but there's confusion over what, under the direction of a doctor, means. Nurses argue. They are more than capable of administering Botox without a doctor being on site. Christina O'Rourke is Chairperson of the Dermatology Aesthetic Nurses Association of Ireland.

Christina O’Rourke DANAI: “If a nurse is safe to administer a medication in a community setting, in a nursing home without a doctor physically present. Why is it required in a Dermatology Aesthetic setting?”

Christina says, nurses administering medication in the health service are trained in the management of anaphylaxis.

“There would be strict expectations for a nurse to have, before administering medication of any description. To have an awareness and a study of anaphylaxis management. This would include many medication management documents that are considered essential.”

Dr. Lisa Cunningham is a consultant in emergency medicine and aesthetic practitioner in Mayo. She says, nurses are already administering Botox in the public system every day without the need for a doctor on site.

Dr. Lisa Cunningham: “Botulinum toxin is a prescription only medicine, so prescription only medicine is administered every day within our public system and within our private system in healthcare in Ireland by registered nurses, advanced nurse practitioners, and clinical nurse specialists without the doctor physically being on site for those applications. They're normally done in a consultant led, or a doctor led service, and we see this every day, either in the nurse department, in oncology, services, endocrinology, gastro, dermatology, all our systems would actually work with this already. So our nurse practitioners are able to deliver prescription-only medicines without the doctor necessarily being right beside the nurse practitioner.”

But Dr. Sean Fitzpatrick disagrees and says nurses administering Botox must be closely supervised by a doctor.

Dr Sean Fitzpatrick: “Nurses administer medications in hospitals, and wards, out in the community. But in all of those situations there is always a doctor on call in the hospital at 2 in the morning. There's an intern, an sho, a reg, a consultant, all available to intervene immediately if something goes wrong. Likewise in the community, you have GP’s on call who are supervising those medications and are responsible for intervening. This is not a like for like comparison".

Dr. Fitzpatrick says he wants to work with nurses to come up with a solution.

Dr Sean Fitzpatrick:  “The main issue is that non-medics, the people who have no medical background, the hairdressers, the nail technicians who open up dermal filler clinics in the back street of a house. They're the real concern here. That's what we're really going after squabbling between doctors and nurses over who gets to administer Botox. That is the battle, you know there is a bigger picture here.”

The Health Products Regulatory Authority (HPRA) which regulates Botox says it doesn't have a role in the regulation of healthcare professionals injecting Botox. It says, the supervision of this administration is a matter for the professional regulatory bodies.

The Nursing and Midwifery Board of Ireland (NMBI), which oversees the regulation of nurses, says it is aware there is a demand for further clarity surrounding Botox administration, and it says it's working to provide that clarity.

Meanwhile the Medical Council says it's working with the Health Products Regulatory Authority (HPRA), and the Nursing and Midwifery Board of Ireland (NMBI) on how they can approach these issues as regulators to ensure that patient safety remains a priority in the absence of clear legislation Dr. Sean Fitzpatrick is calling for more clarity and says the law is open to interpretation.

Dr. Sean Fitzpatrick; “So, we need clarity from the HPRA in terms of what exactly do you understand As the regulator, as the enforcer of Botox administration of the term under the direct supervision of’."

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That was Dr. Sean Fitzpatrick, ending that report from Aisling Kenny.