As you would be aware APAN is heavily involved in regulatory processes, particularly with issues of health and education. 

These initiatives are required to undergo in-depth and extensive work in both the investigative process as well as in the drafting of proposed standards.  From there they need to be presented to the relevant department to ensure the structure is approved by the appropriate government agencies. Following this, they need to meet with stakeholder approval and finally, a Regulatory Impact Statement will need to be circulated for public comment before it is introduced. Currently, we are working on three initiatives as follows:


In our previous report UPDATE ON THE REGULATORY PROCESS OF BODY ART AND COSMETIC TATTOO INKS (APJ Volume 47 winter 2021) we presented an update on the investigation of evidence that various tattoo inks and pigments reported being considered hazardous and carcinogenic and their proposed removal from formulas through the introduction of regulation.

While the regulatory proposal was halted by the Queensland Department of Health pending further investigations, this process has subsequently been rigorously pursued by Queensland Health. 

On 28th October, we received correspondence from Queensland Health (Environmental Hazards, Unit, Health Protection Branch notifying us that we can anticipate that the review of the Departmental Standard will be completed by the end of November. A copy of the draft revision will be forwarded to APAN. Once we receive the draft a further meeting with Queensland Health will be determined, once we have the opportunity to review the draft.

The issue of both practitioner and consumer safety will always remain a high priority for APAN and we will relentlessly pursue these issues to ensure they reach a regulatory outcome. There is sufficient evidence of confirmed hazardous pigments and inks and it is important that a regulatory instrument is introduced to request their removal from future product formulations.


While several states have certain licencing requirements for laser and IPL, overall, the standards are inconsistent from state to state.  For example, Queensland and WA standards are only in place for Lasers and not for IPL. 

A recent research report undertaken by Alex Korenevski through the University of Queensland entitled Regulation of Intense Pulsed Light (IPL) Treatment in Queensland identified the ongoing burns and permanent injuries that are possible not just with lasers, but also with IPLs. The report proposed that there is sufficient evidence to urge that both lasers and IPLs should be regulated for use for cosmetic purposes. To access further information on this research report please check out our interview with Alex on our YouTube Channel SOLUTIONS FOR AESTHETICS by APAN.  You will find this on the APAN website


At the end of August this year, we were approached by the NSW Environmental Protection Authority who was undergoing a review of the NSW Radiation Control Act 1990, requesting that we submit our recommendations for potential regulations for IPL and Laser for NSW.  Following the review of their proposed paper, on 19 September 2021 APAN submitted a comprehensive report, supported by ongoing evidence of burns stressing the need for a regulatory framework for the use of IPL and Laser for cosmetic purposes. Our report was very well received as it provided validated evidence to necessitate the consideration of regulatory framework for NSW.

Having a history of industry involvement allowed APAN to also present the comprehensive Complaints Submission regarding Universal Medical Aesthetic (UMA) when over 100 businesses suffered extensive financial losses because of faulty and poor-quality IPL devices.  This report was presented to the TGA, ARPANSA, the ACCC and the Federal Small Business Ombudsman in 2016, but no action was taken against this company, which subsequently went into liquidation leaving numerous businesses stranded with malfunctioning devices. However, this 60-page report, which contained incredible data on this incident, was now able to be retrieved (at the request of the NSW Environmental Protection Authority) to be included in our submission for the NSW Radiation Control Act 1990 review.


On October 7, we were contacted by Environmental Health, formally known as enHealth, presenting us with a draft proposal for a National Strategy for Radiation Safety and its Implementation Plan.

The plan was released by the Federal Department of Health for public consultation. This is a huge move in the right direction.  We are currently reviewing this document and will are in the process of submitting our recommendations. 

The draft National Strategy and its Implementation Plan have been developed in partnership with the states and territories.  It is an important step towards developing a national approach to managing radiation safety across the country and has been endorsed by the Australian Health Protection Principal Committee (AHPPC).

A review of Australia’s systems for radiation safety by the International Atomic Energy Agency identified opportunities for Australian governments to improve the consistency of regulation across the country.

It is important that Australia’s framework for radiation safety is flexible and responsive to future challenges and emerging technologies, and that all Australians are able to benefit from these technologies and have confidence in their safety. The draft National Strategy aims to develop a consistent approach to radiation protection across Australia. It focuses on bringing the existing elements of radiation safety together to ensure a more cohesive and harmonized approach is followed across the country.

The purpose of this consultation is to seek feedback from stakeholders and users of radiation technologies on the draft National Strategy and its Implementation Plan. Our input will be used to further develop and refine these documents. The finalisation of the National Strategy is a key step toward in establishing an intergovernmental agreement between Commonwealth, state, and territory governments for the regulation of radiation safety. We were strongly encouraged to provide feedback on the Strategy. Our final report must be submitted on December 7, 2021.

The good news is that enHealth has the authority to sign off on regulation as they have the power to do so. Furthermore, we believe establishing an Implementation Plan across all states will be a positive step forward towards national regulation which we desperately need.

This is a major step, but not a simple one.  However, as we are establishing dialogue and communication with enHealth there appears to be light at the end of the tunnel. We will keep you posted on developments.