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    Skin Penetration Procedure Compliance Guidelines

    Preparation of the Skin and Clinic for Non‑Surgical Skin Penetration Procedures

    Non‑surgical skin penetration procedures (SPP) are subject to increasing regulatory scrutiny, with a strong focus on hygiene, infection prevention and practitioner competency. These guidelines have been developed to support practitioners and clinic owners in maintaining safe, compliant and audit-ready practice.

    Purpose of This Guide

    This resource provides clear, practical direction on the procedural requirements immediately surrounding an SPP. It is designed to help practitioners uphold consistent standards of infection control and meet their compliance obligations with confidence.

    Scope of This Guide

    This guide focuses specifically on the requirements:

    • Before a procedure
    • During a procedure
    • After a procedure

    It does not comprehensively address broader operational responsibilities such as premises design, environmental controls, staff training and qualifications, or organisational governance. Practitioners should refer to the standards and guidelines listed in the Regulatory Framework section below to ensure full compliance with all legislative and professional obligations.

    Supporting Tools for Compliance

    To assist with day-to-day implementation, we’ve developed an SPP Checklist as a practical tool to support consistent, audit-ready practice. It is designed to:

    • Assist in systematically meeting national guidelines
    • Promote consistent infection control standards
    • Support clinics in maintaining accurate, audit-ready documentation
    • Streamline procedural compliance

    The Purifas SPP Checklist: A one‑page printable checklist covering hygiene, infection control, equipment safety and practitioner readiness.


     

    Skin Penetration Procedures

    The Public Health Act 2010 defines an SPP as:

     

    “

    Any procedure (whether medical or not) that involves skin penetration (such as acupuncture, tattooing, ear piercing or hair removal, or the penetration of a mucous membrane), and includes any procedure declared by the regulations to be a skin penetration procedure.

    These guidelines also apply to practitioners performing non-surgical cosmetic procedures, including injectables and facials that involve microdermabrasion, needling and extractions.

    If you are unsure whether a procedure falls into the definition of skin penetration, please contact your local council for clarification. (Laser hair removal is not classified as an SPP under the Public Health Act.)

    Regulatory Framework

    Non-surgical SPPs in Australia are governed by a combination of national standards, clinical guidelines and state or territory public health legislation. These requirements regulate all aspects of practice, including the treatment environment, infection prevention and control, equipment reprocessing, sharps management and client safety.

    National Standards and Guidelines

    Our checklist has been developed directly from, and is aligned with, the following national standards and regulatory guidance:

    • AHPRA: Guidelines for registered health practitioners who perform non-surgical cosmetic procedures
    • AS 5369:2023: Reprocessing of reusable medical devices and other devices in health and non-health related facilities
    • AS 23907:2023: Reusable containers for the collection of sharp items used in human and animal medical applications
    • National Health and Medical Research Council (NHMRC): Australian Guidelines for the Prevention and Control of Infection in Healthcare

    The checklist consolidates these requirements into a practical operational tool to support safe practice, infection control and audit-ready compliance.

    State and Territory Legislation

    In addition to national standards, SPPs are regulated under state and territory public health legislation. Practitioners must review and comply with the requirements specific to their jurisdiction, alongside our checklist and their internal policies, to ensure full regulatory compliance.

    Inspections and Audits

    Premises conducting SPPs are subject to routine inspections and audits by regulatory authorities, including local councils, state health departments (e.g., NSW Health) and AHPRA where applicable. These assessments typically review compliance across multiple areas, including:

    • The physical treatment environment
    • Infection prevention and control practices
    • Client preparation procedures
    • Treatment techniques
    • Sharps handling and waste disposal
    • Cleaning, disinfection and sterilisation processes

    Audits are conducted to ensure adherence to public health regulations and recognised national standards, including the NHMRC’s Australian Guidelines for the Prevention and Control of Infection in Healthcare.

    Record-Keeping Requirements

    Under public health legislation, procedure records must be retained for a minimum of 12 months. However, because compliance audits may occur at any time, it is strongly recommended that records be retained for as long as practicable. Registered health practitioners must retain adult patient health records for a minimum of seven years, in accordance with their professional regulatory obligations.

    Conclusion – A Practical Path to Confident Compliance

    Maintaining high standards in SPPs does not need to feel overwhelming. With the right systems in place, compliance becomes part of everyday practice rather than an added burden.

    Our SPP Checklist has been developed to support this. It brings together national standards and public health requirements into one practical, easy-to-use tool that promotes consistency, safety and audit-ready practice.

    By incorporating the checklist into your routine processes, you are not only supporting compliance — you are strengthening patient trust and reinforcing the professionalism of your clinic.

    Additional Resources

    For broader guidance, these requirements sit alongside our Best Practice Guidelines, which outline the core standards for all clinic and shared treatment settings.

     

     

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