It’s Time to Regulate Laser Treatment for Safety’s Sake

 In Blog

It’s dangerous out there – yes COVID-19, but it’s more than that….

Phase 1.

Phase 2.

Directive #2.

COVID-19 is a confusing, ever changing series of directives, legislation, openings, closings, masks, no masks, gather, don’t gather, inside, outside… what’s a clinic to do?

Can you book a treatment? Which treatment?  Which part of the body?  With which practitioner?  Is that allowed? Or is it not?

We’ll be honest with you; it’s confusing for us as well.

But this is what we do know for sure.  Regulated health professionals are allowed to be open their offices and offer care.  This includes doctors, dentists, optometrists, massage therapists, naturopaths, physiotherapists, chiropractors, nurses etc.  Directive # 2 issued May 26/20 in Ontario allows regulated health providers (under the oversight of a governing college) to return to providing in-person care which includes examining and treating any part of the body.

Inside a regulated health professional’s office, there are staff.  Sometimes the staff are regulated health professionals as well and sometimes they are not.  For example, a dentist works with dental hygienists who are also regulated and can therefore provide care without restrictions.  However, if the dentist or orthodontist has dental assistants who are not regulated who might take x-rays, or make dental molds, adjust braces – this is not allowed under the current legislation.

Why is this? Unregulated Personal Care Service providers (such as hairstylists, beauty salons, cosmetology shops, tattoo parlours, day spas etc) are prohibited from providing services that involve touching the face according to Ontario’s Phase 2 framework document.

Is a dental assistant a personal care service worker?  That’s arguable.  My opinion is that as long as they are working under the direct supervision of the regulated dentist, they are a heath care provider’s delegate and not an independent personal care services provider.  Nonetheless, from a strict reading of the Phase 2 directive if that staff member is unregulated they may not perform services involving the face, ears, mouth or eyes.

At ArtMed, we are fielding a lot of questions about whether facial laser services can be provided at our clinic under the current legislation. Our facial services are performed by our medical laser technicians.

Believe it or not Ontario does not regulate laser technology. Consequently, medical laser technicians are unregulated health professionals.  Even though medical laser technologists attend college level programs where they receive diplomas, and these colleges typically adhere to international training standards, Ontario hasn’t regulated laser technology training and thus specific training isn’t a requirement to operate a laser.

Aesthetic lasers are medical lasers.  They are Class IV medical devices, the most dangerous type of lasers and they are used for medical, scientific, industrial and military applications.  Should their use be regulated? YES. For years, the Canadian Dermatology Association has been calling for regulation of aesthetic treatments including lasers.

In my experience, laser technicians are like other technicians.  They attend school to learn about a very complex technology and how to use that technology safely and appropriately.  Think of ultrasonographers, x-ray technicians, MRI technologists etc.  It takes schooling, training and years of experience to safely and effectively employ these technologies.  Let me be clear, just because I’m a doctor, or she’s a nurse, doesn’t mean we’re qualified as an ultrasonographer, an x-ray technician or a medical laser technician.  But I also believe that Ontario should unify and regulate the educational standards for laser technicians and bring them under the umbrella of regulated health professionals.

So what does this mean in Ontario right now?  Clinics are not allowed to have their trained medical laser technicians provide treatment to a patient’s face.  However, many aesthetic clinics also employ nurse injectors who are regulated health professionals.  And because laser treatment is unregulated, these same nurses can just step in and run that laser for treatments on a patient’s face.  Should they?  Are they sufficiently trained?  Do they have a diploma in laser technology?  Did they do this as a routine part of the day to day practice prior to COVID?  If not, I believe they should not be providing laser treatments.  I do not feel they are sufficiently qualified to safely do so.


  • Do these clinics have a Laser Safety Officer who has undertaken Aesthetic Laser Safety Officer Training?
  • Is the clinic adhering to all the requirements set out by CLS (Canadian Laser Safety administrative authority)?
  • Has the laser operator had an eye exam for the purpose of baseline documentation prior to operating a laser?
  • Do they have current first aid training certificates?
  • Do they have documented laser operator credentials, training or education they can produce?
  • Have they been certified to run that particular laser by the company that makes the laser?
  • Is the room in which they operate the laser meeting the long list of safety requirements set out by CLS?
  • Do they have the appropriate safety equipment in place for the operator and the patient?
  • Are they adhering to full PPE for plume generating procedures (eg. laser hair removal) including N95 masks, gowns, gloves, shields and appropriate surgical level ventilation systems (especially during COVID?).

This is why we need regulation.

This is why we need medical laser technicians to operate lasers.  A nurse injector at an aesthetics clinic shouldn’t just step into that role just because she can due to regulatory loopholes and blind spots.  And nurses (or doctors) shouldn’t just step into running lasers for facial procedures during COVID if they aren’t adequately trained, weren’t regularly doing this before these COVID directives came into effect, or don’t have appropriate PPE or ventilation systems in place.

As always, when it comes to medical aesthetics it’s a bit of the wild west.  And for the patients it’s buyer beware. Safety beware.

At ArtMed, our medical laser technicians are not able to provide aesthetic facial treatments at present because they have been categorized as personal care providers because they are not regulated.  I personally believe medical laser technicians should be able to provide care. I tried to make the case with Public Health that it is the most responsible and safest thing to do.  It would be safer than allowing untrained regulated health professionals to step into this vacuum.  But because of the vagaries of the legislation (or lack thereof), Public Health has no choice but to say that medical laser technologists cannot provide these facial services (but other regulated health professionals can do so even if untrained).

We also contacted the Ontario Health System Emergency Management Branch seeking direction with respect to this issue.  They advised us that because laser treatments are not ‘controlled acts’ they cannot be delegated by a physician to a laser technician at this time. Only controlled acts can be delegated.

What is a controlled act?

There are 14 controlled acts in the Regulated Health Professions Act, 1991. Ontario Health SEMB stated, ‘a controlled act can cause harm if it is performed by an individual who is not competent(controlled acts include providing injections, setting a fracture, prescribing medication to name a few).

Clearly, operating a Class IV laser without proper training is very dangerous and has great potential to cause harm. And yet this type of treatment has not been deemed a controlled act in Ontario. Consequently, a physician cannot delegate this treatment to a laser technician currently, and with the current Phase 2 restrictions in place, laser technicians cannot do facial treatments because they are unregulated. Thus we have the perfect storm – trained technicians unable to do their job, untrained regulated professionals stepping into the void, and the potential to cause harm rising consequently.

I am not alone in this concern.  A joint position statement calling for regulation in the practice of aesthetics including lasers was published in 2016 with the following signatories:

The Canadian Society for Aesthetic Plastic Surgery

The Canadian Dermatology Association

Canadian Laser and Aesthetic Specialists Society

Canadian Society for Dermatologic Surgery

Canadian Association for Accreditation of Ambulatory Surgical Facilities

It’s been a problem for years, and COVID-19 regulations have made the situation all that more dangerous.

I believe medical laser technicians are medical professionals not personal care service providers especially with respect to treating medical skin conditions including scars, acne, rosacea, lesions etc.  I also believe that medical clinics (overseen by an on-site physician or nurse practitioner) that offer laser treatments to the face for their patients with medical conditions should be allowed to operate right now just like other medical offices can (dentists, optometrists, orthodontists, family physicians etc).

Purely aesthetic treatments are optional, and they can wait if that is what the province deems appropriate.  But right now, patients who do have medical conditions that are treated with laser should have access to that care, and they should be able to have that treatment done under physician oversight and by professionals appropriate trained to do that  – medical laser technicians.


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  • Vincent

    It is really a informative article…excellent work

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