4 December 2019
During a routine inspection
Baruch Hair Transplant Centre Limited is operated by Baruch Hair Transplant Centre Limited (BHTC). Facilities include a hair transplant treatment room, a recovery area and a consultation room. The service has no overnight beds. The service provides surgical hair transplant procedures only. There are two methods of hair transplantation: follicular unit transplant and follicular unit extraction. The service only provided follicular unit extraction. In follicular unit extraction individual follicles are extracted and then implanted into small excisions in the patient’s scalp.
We found several areas of concern during our last inspection on the 27 June 2019; however, the immediate risk to patients was low due to the number of procedures undertaken by the service. Immediately following the inspection, we requested evidence from the provider under section 64 and section 65 of the Care Standards Act for further assurance of the safety of patients using the service.
We inspected this service using our focused inspection methodology. We carried out the announced part of the inspection on 4 December 2019. We focused on specific parts of the service which were identified as inadequate since our last inspection. The key questions we asked during this inspection were, was it safe, effective, responsive and well-led. Due to the inspection being focussed we did not rate this inspection.
Following this inspection, we carried out enforcement action and served a notice under Section 31 of the Health and Social Care Act 2008 to suspend the registration of the service provider in respect of the regulated activities: surgical procedures.
We also served a warning notice under section 29 of the Health & Social Care Act 2008. This warning notice was given because we believe that a person will or may be exposed to the risk of harm if we did not take this action.
Services we rate
Due to the inspection being focussed we did not rate the service.
We found the following issues needed further improvement:
- Invasive procedures, such as hair transplants, require clinical ventilation to reduce the risk of surgical site infection. However, we inspected the treatment room during the inspection on 4 December 2019 and saw that there was no specialist ventilation provision. This was not in line with the department of health HTM guidance 03-01. This posed a risk of surgical site infection as hair transplants are invasive procedures involving multiple surgical incisions over several hours.
- Consent was not obtained in line with the Royal College of Surgeons (RCS) Professional Standards for Cosmetic Surgery (April 2016) which states that, consent should be gained by the doctor who will be delivering treatment, 14 days prior to treatment, to ensure the patient has a cooling-off period.
- The policy and process for monitoring a deteriorating patient was not robust or embedded into practice.
- Although the registered manager had plans to improve governance structures to monitor and improve the quality and safety of the services they provided; these had not been implemented following the last inspection in June 2019.
- The action plan submitted by the provider following the last inspection in June 2019 had not been fully completed by the provider, actions remained incomplete.
- We saw limited evidence that management used systems to manage performance effectively. Audit practice was not robust or embedded into practice.
- The provider had improved governance processes surrounding hand hygiene and the recording of fridge temperatures;
- The provider had instigated a process to monitor patient feedback; however, audit of this feedback had not yet commenced.
- Whilst risks and issues were identified and escalated, there was limited evidence to show actions to reassess and reduce their impact.
- The safeguarding policy had not been revised following the last inspection in June 2019. The policy in use was generic with no amendments for safe systems and processes surrounding recognising vulnerable adults at risk and onwards referral to external agencies.
- There was not an effective incident reporting and management process in place.
- There was no evidence the service used any national guidance for cosmetic surgery.
- The service held no staff meetings or evidence of staff involvement in running the service.
- There were limited systems to improve service quality and safeguard high standards of care.
- Although the service had a vision for what it wanted to achieve, the strategy to turn it into action was not yet in place despite this being identified as a concern at our previous inspection.
However;
- We were assured that there was a process in place to ensure that all staff had undertaken mandatory and safeguarding adults training. Prior to a clinical procedure being undertaken staff training was checked to ensure compliance.
- The provider had improved training requirements to ensure staff had the relevant qualifications, competence, skills and experience to care for patients safely.
- The provider had instigated the World Health Organisation (WHO) safety check list process into practice.
- Clinical waste streams were managed appropriately in line with guidance.
Following review of the provider action plan, which had been drafted and completed by the provider following the last inspection, we suspended this inspection, because we were not assured that the provider had made substantive changes to practice following the last inspection.
We served an urgent notice of suspension to the provider in January 2020 following review of data requests submitted post inspection.
Following this inspection, we told the provider that regulations had been breached and the service needed to improve. Details are at the end of the report.
Ann Ford
Deputy Chief Inspector of Hospitals (North)