Harley Street Skin – Hannah House is operated by Skin@harleystreet LLP. The service provides

cosmetic surgery and other cosmetic treatments to people over the age of 18 years. The clinic does not have in-patient beds. Facilities include two operating theatres and a three chaired pre assessment/recovery room. The outpatient consultation prior to the procedure itself is provided at the provider’s main Harley Street Skin Clinic at Harley Street which is registered as a separate location and was not inspected as part of this process.

At our last comprehensive inspection of this service on 18 January 2017, we found the following issues that the service provider needed to improve:

• There was no system for checking the expiry date of medicines.

• There was no system for checking the expiry date of single-use items.

• Though there was a system for checking the resuscitation trolley, we found expired single-use items upon checking the trolley.

• There were no records of safety checks on portable equipment or evidence of equipment maintenance.

• The clinic did not use the World Health Organisation (WHO) safety checklist for day surgery cases and the ‘5 steps to safer surgery’ were not used.

• There were very limited competency records held for nursing and theatre staff members.

• There was no evidence to show that staff had up to date safeguarding training.

• There were no formal meetings, including medical advisory committees (MACs) and governance meetings. There was no formal governance structure in place.

• The Disclosure and Barring Service (DBS) records of some of the clinical staff were not up to date.

• There was no clinical audit plan in place. Although consultants reviewed their own cases on a regular basis, there was no formal documentation audit or consent audit.

• There was no documented admission policy

The hospital was in breach of three regulatory requirements and we issued a Warning Notice on 3 April 2017 for the following breaches:

• Regulation 12 HSCA (RA) Regulations 2014. Safe care and treatment.

• Regulation 17 HSCA (RA) Regulations 2014. Good governance.

• Regulation 19 HSCA (RA) Regulations 2014 Fit and proper persons employed.

The purpose of this inspection was to check whether the provider had complied with the Warning Notice. We inspected this service using our focused inspection methodology, which included an unannounced visit to the clinic on 11 July 2017.

We found that the provider had made improvements to the service, which complied with the Section 29 Warning Notice.

Our key findings were as follows:

• There was a system in place for checking the expiry date of medicines.

• There was a system for checking the resuscitation trolley.

• The provider had made significant progress with monitoring and keeping records of safety checks on portable equipment. There was evidence of equipment maintenance.

• The clinic used the World Health Organisation (WHO) safety checklist for day surgery cases.

• Staff told us safety huddles had been introduced before the start of every theatre list, led by the lead physician.

• There were sufficient competency records held for all nursing and theatre staff members.

• All staff had up-to-date safeguarding training.

• There was a system to follow up patients within 24 hours post-operatively.

• The provider had established a medical advisory committee (MAC) and initiated the process of formal meetings. We saw evidence of their first meeting, which was held on 18 May 2017.

• The Disclosure and Barring Service (DBS) records of the majority of the clinical staff were up to date. For any remaining staff, their applications were in process and we saw evidence of this.

• There was a clinical audit programme in place, which included a documentation audit and a consent audit.

• There was a documented admission policy in place.

• All staff had up-to-date mandatory training, including basic and advanced life support training.

However, the provider is still required to make further improvements regarding the following:

• There was an improved system for checking the stock and expiry date of single-use items. However, we still found some single-use items that were expired, although the provider told us that these were no longer in use.

• The pre-assessment questionnaires were not fully comprehensive and all aspects of a patient’s history were not covered during the pre-assessment process. This included psychological assessment and mental capacity.

• There were gaps in assurance regarding the cleaning of the premises as we found dust on high surface areas.

• The provider’s Medical Advisory Committee was not yet fully embedded.

• Staff team meetings had been introduced sine the last inspection, but were not held regularly.

Services we do not rate

• We regulate cosmetic surgery services but we do not currently have a legal duty to rate them. We highlight good practice and issues that service providers need to improve and take regulatory action as necessary.

Professor Edward Baker

Chief Inspector of Hospitals