Archived: Harley Cosmetic Group

Harley Cosmetic Group is operated by LXIR Medical Ltd. It is a private cosmetic and dental clinic in central London. The cosmetic service is a consultant-led provider of cosmetic services. There is one consultant working for the service. No surgical procedures requiring general anaesthetic are undertaken at the location. Patients requiring general anaesthetic surgery are referred to an independent private clinic in Harley Street, London.

The main service provided by this service is cosmetic procedures and dental services. There was one registered manager for both cosmetic procedures and dental services.

Patients at Harley Cosmetic Group are seen for a full range of dental procedures and pre- and post-operation cosmetic consultations, for example, liposuction, (this is a type of fat-removal procedure). Patients can self-refer or are referred from the Harley Body Clinic referral website. All procedures are performed by the Harley Cosmetic Group.

The cosmetic service operates from Monday to Friday, with occasional Saturday clinics. The dental service operates on Monday and Thursday.

The service primarily serves the communities of the London area. It also accepts patient referrals from outside this area. The provider is registered for the regulated activities: treatment of disease, disorder or injury, surgical procedures and diagnostic and screening procedures.

We carried out an unannounced responsive inspection, in response to concerns received, at the Harley Cosmetic Group on Wednesday 1 December 2021 and Friday 3 December 2021. The provider had not been previously inspected.

We rated Harley Cosmetic Group as inadequate overall because:

• The service did not ensure staff received effective training in safety systems, processes and practices. We requested mandatory training records documentation for all staff. We were not provided with evidence of formal training records and evidence of where the training had taken place.
• Staff told us they had completed basic life support training. We requested these records during the inspection. However, these were not produced.
• We found the policy on the management of deteriorating patients did not identify a clear escalation pathway. We asked for evidence of a service level agreement in the event of a patient needing to be transferred to another facility. However, we were told these were not yet in place.
• The service did not have a documented pathway for patients’ journeys through treatment including: assessment, planning, implementation and review. We did not see evidence of pre-surgical risk assessments.
• The service did not ensure medications were safely stored. We saw medicines stored in an unlocked theatre medicines fridge and unlocked consultation room cupboard. There was a risk because the fridge and cupboard could be accessed by unauthorised persons.
• We found loose medicines in the theatre medicines fridge and consultation room cabinet.
• We found out of date medicines in the theatre fridge and consultation room cabinet. There was no system of medicines audit or stock control. This posed a risk that out of date medicines were not being monitored by the service and patients could be given out of date medicines.
• The service did not adhere to their policies relating to the management of clinical waste. We saw clinical waste in an orange plastic bag on the floor in the sluice room. The sluice room was also used to store clinical dressings. There was a risk of cross-contamination.
• We found an open sharps bin in the theatre containing used syringes and needles. There was a risk of sharps bins being knocked over and potentially causing needle stick injuries.
• We saw an electrical safety testing sticker on the base of the electric treatment table in the theatre which showed it had not been serviced since 2019.
• We asked to see all patient records and were not provided with evidence of full individual patient care records including risk assessments. We were told the service did not have access to the records as they had been sent to be digitised. However, the coordinator produced three pre-procedure assessment records., but these were not full patient records detailing treatment, patient details or clinician providing treatment.
• Patients records were not stored securely. We were told that patient records were being held at a person’s house who was not employed by the service. This is a breach of patient confidentiality.
• All policies we reviewed were dated 2019 and had no review dates or version controls.
• The service did not have service level agreement in place for patients that were referred to another provider in the event of an emergency.
• The service did not have a service level agreement in place for patients referred to another independent provider, who provided procedures requiring general anaesthesia on behalf of Harley Cosmetic Group.
• The registered manager was not aware of doctors’ practising privileges. Staff told us the consultant had an informal agreement with the dentist, who was the registered manager. However, this agreement was undocumented.
• The registered manager was unable to show us if all staff had had pre-employment checks. We asked for personnel files, but we were told that they did not exist.
• There was no evidence that staff had Disclosure and Barring Service (DBS) checks in place.
• We requested fire risk assessments and Control of Substances Hazardous Health (COSHH) risk assessments and were provided with risk assessments for communal areas of the building only. Staff told us risk assessments for the clinical areas of the service on the fourth floor had not been completed.
• We were not provided with evidence of any systems of audit or risk management systems such as medicines audits, COSHH audits, or a risk register.
• We asked the registered manager for information on how the cosmetic surgery side of the service was managed and run. They told us they were unaware of the details of how the cosmetic service was managed and run.

However:

• We spoke with two patients during our inspection. The patients we spoke with gave positive feedback about the service. They told us staff treated them well and with kindness.

As a result of this inspection, we took urgent action to suspend the registration of the provider for an initial period of eight weeks. We told the provider they must take actions to comply with the regulations and that it should make other improvements. These can be found at the end of the report.

Professor Ted Baker, Chief Inspector of Hospitals said: I am placing the service into special measures. Services placed in special measures will be inspected again within six months. If sufficient improvements have not been made, such that there remains a rating of inadequate overall or for any key question or core service, we will take action in line with our enforcement procedures to begin the process of preventing the provider from operating the service. This will lead to cancelling their registration or to varying the terms of their registration within six months if they do not improve. The service will be kept under review and, if needed, could be escalated to urgent enforcement action. Where necessary another inspection will be conducted within a further six months, and if there is not enough improvement we will move to close the service by adopting our proposal to vary the provider’s registration to remove this location or cancel the provider’s registration. In addition, we will inspect this service again toward the end of the period of suspension to check if the suspension can be lifted or if it needs to be extended,

Nigel Acheson

Deputy Chief Inspector of Hospitals, on behalf of the Chief Inspector of Hospitals