Consultation & Feedback
As part of the ASDC mission to advocate for members, we participate in government and other forums providing feedback on matters relating to skin health practitioners. We work to increase awareness and opportunities for employment, increased scope of practice and recognition for our expertise. Below are some of the projects currently under review with the ASDC. We encourage members to read and provide their valuable feedback in our preparation of submissions.
Submitted 14 August, 2023
Australian and New Zealand Standard Classification of Occupations (ANZSCO) -Comprehensive Review
The ABS continues its comprehensive review of the Australian and New Zealand Standard Classification of Occupations (ANZSCO) to reflect the contemporary labour market and better meet stakeholders’ needs.
AHPA coordinated a workshop with the Australian Bureau of Statistics and AHPA members for the ABS to provide background on the changes to Australian Occupation Classifications (ANZSCO), and give AHPA members an opportunity to ask questions and provide initial feedback on the ABS project.
AHPA members provided excellent feedback and insight into the nature of their professions to inform the reorganisation of the classification on behalf of all allied health professions.
The workshop explored the possibility of the ANZSCO being re-defined to reflect allied health occupations as a grouping of professions in the same way nurses, doctors and teachers are classified together.
The ASDC also submitted a response on behalf of Dermal Clinicians and Therapists who are as yet not represented with their own professional title or ANZSCO code.
A final consultation round in 2024 will allow users opportunity to provide feedback on the complete set of proposed changes prior to finalising the classification update for release by December 2024.
Feedback Due 30 November
National Strategy for Radiation Safety and Implementation Plan
The ASDC and its members have been identified as Stakeholders in the Draft National Strategy for Radiation Safety and Implementation Plan. The draft National Strategy and Its Implementation Plan has been developed in partnership with the states and territories and is an important step towards developing a national approach to managing radiation safety across the country and has been endorsed by the Australian Health Protection Principal Committee (AHPPC).
As an ASDC member, this is your opportunity to provide valuable input into the future best practices in our industry.
Please download the Draft Implementation Plan for Radiation Safety here and send any feedback you have to email@example.com no later than 30 November 2021. Responses will be collated and a formalised response forwarded to the Australian Health Protection Principal Committee (AHPPC) by 7 December 2021.
Submitted 19 September 2021
Review of NSW radiation safety ACT 1990
Section 39B of the Radiation Control Act 1990 requires the Minister for Energy and Environment to commence a review of the Act ‘as soon as practicable’ after the 10-year anniversary of changes made by the Radiation Control Amendment Act 2010 (RC Amendment Act). This anniversary occurred on 4 November 2020. The terms of the review are: To determine whether the policy objectives of the Act remain valid and whether the terms of the Act remain appropriate in securing those objectives. The Minister must table a report on the outcome of the review in Parliament. The review is intended to ensure that the Act: • remains robust, modern and fit-for-purpose legislation, giving effect to applicable national codes, standards and guidance • continues to provide a high level of protection for the community and the environment, including the security of high-risk radioactive sources • is equipped to manage contemporary challenges, in a context of scientifically evidence-based policy. All technology is subject to change and innovation and radiation technology is no different. In the medical sphere, there are emerging trends in diagnosis and therapy, along with automation and artificial intelligence in clinical care. Change and innovation also impact commercial activities that use radiation equipment and material. Existing applications of radiation are finding new purposes, which must be appropriately regulated to protect the community and the environment. The Act also needs to remain effective in meeting evolving community expectations on radiation protection of people and the environment and other contemporary social and economic challenges. The review will help ensure that the Act is better able to support business, the safe and beneficial use of radiation and the national economy
Submitted 11 July 2021
Radiation Safety Regulation QLD
The Radiation Safety Regulation 2010 (Qld) (the Regulation) is being remade ahead of its scheduled expiry on 1 September 2021.
Some parts of the Regulation have been re-structured or re-worded to improve clarity and readability. Also, a series of minor amendments are also being made to the Regulation to improve operational effectiveness. These amendments include:
amending the prescribed period for certificates of compliance where a radiation apparatus is used under an approved quality assurance program;
classifying all lasers above Class 1 as radiation apparatus to help ensure all lasers are properly classified and labelled;
clarifying that the Code of Practice for Radiation Protection in Dentistry (2005) applies to both intra- and extra-oral dental diagnostic radiography;
prescribing specific requirements for the disposal of reverse osmosis concentrate to facilitate the regulation of this material;
providing an arrangement for recognising cosmetic laser training courses which will qualify a person for an exemption from the requirement to hold a use licence while undergoing training;
increasing the list of radiation sources that are exempt from the requirements of parts of the Act;
updating the list of authorised persons who are allowed to prescribe therapeutic or request diagnostic procedures;
updating and simplifying the provisions relating to fees;
updating references to outdated documents;
updating various definitions for terms used in the Regulation.
A copy of the draft Radiation Safety Regulation 2021, together with a consultation paper are attached for your reference.
Submitted 9 June 2021
Proposed legislation to alter the use of tattoo ink in Queensland
The QLD health department began a review into the need to for further regulation of tattoo inks.
The Australian Society of Dermal Clinicians (ASDC) is writing to provide our views in relation to the increased regulation of tattoo inks in Queensland.
We provide these views as an industry body representing professional skin health practitioners that provide health services directly impacted by concerns of the safety of tattoo inks. This includes providing cosmetic and remedial micropigmentation (tattoos) and the correction and management of some tattoo associated complications involving the skin such as wound healing and fibrosis, scarring or exacerbation of pre-existing skin conditions and removal of tattoos using LASER techniques. As an industry organisation, we advocate for safety and standards of care for consumers receiving skin therapies and the provision of therapy utilising an evidence-based approach
Submitted 2 July 2021
Feedback on SHB60219 Advanced Diploma of Skin Therapy Draft 2
The Australian Society of Dermal Clinicians (ASDC) is writing to provide feedback on the above
We provide this feedback as an industry body representing professional skin health practitioners
from various industry backgrounds and educational levels, including vocational and higher education.
Our members have also provided feedback that we have collated from their perspectives as industry
employers of potential graduates of this program and industry peers working within the aesthetic
Ongoing / Draft 2
Primary Health Reform Draft Recommendations – Consultation
The Australian government is calling for stakeholder input following the opening of the consultation period for the draft Primary Health Care 10 Year Plan.
Primary health care matters to everyone. It is the front line and first point of contact with the health care system for most Australians, and it is central to keeping people healthy and well in the community, wherever they may live and across all stages of their lives. Our primary care system is world class and has been a central driving force at the heart of our COVID-19 response.
Over the last two years, the COVID-19 pandemic has compelled healthcare systems around the world to change the way they operate and deliver health care practically overnight. The Primary Care sector has underpinned our COVID response in communities across Australia, we have accelerated the use of telehealth as part of usual care and highlighted the value of local collaboration across providers and systems to save and protect lives.
We need to ensure that our system can continue to deliver the best, contemporary health care, to meet today’s and tomorrow’s health challenges.
The Australian Government recognises the immense value of primary health care in providing high quality outcomes and experiences for all Australians. In August 2019, the Government announced the development of a Primary Health Care 10 Year Plan as part of Australia’s Long Term National Health Plan.
While the pandemic represents a once-in-a-generation challenge for healthcare systems, it also represents a once-in-a-generation opportunity to harness this unprecedented momentum, to work with an industry that has been primed for change through its experience of operating in the conditions of a global pandemic.
The Plan draws on input from consultations with individuals and organisations across the country from late 2019, and during 2020 and 2021. It represents a high-level response to the recommendations of the Primary Health Reform Steering Group, which has been working since October 2019 on future directions for primary health care reform.
The focus of the 10 Year Plan is on Australia’s primary health care services provided through general practices, Aboriginal Community Controlled Health Services (ACCHS), community pharmacies, allied health services, mental health services, community health and community nursing services and dental and oral health services.
The Plan also focuses on the integration of primary health care with hospitals and other parts of the health system, aged care, disability care and social care systems.
You can now provide feedback on the draft plan, and individuals and organisations with an interest in primary health care and what a future focused system can deliver for all Australians are encouraged to share their views. Written submissions can be provided until 11:59pm, 9 November 2021 at https://consultations.health.gov.au/primary-care-mental-health-division/draft-primary-health-care-10-year-plan
Ongoing - Open Feedback
ASDC Governance Reform - Self Regulation
The ASDC is currently reviewing its governance documentation, policies and procedures in preparation for applying for self regulatory status with NASRAHP in 2022. For more information you can investigate the ASDC strategic direction and plan.
In preparing for self regulation, the ASDC utilises consultant services including Associations Forum, Maddox Lawyers and Allied Health Professions Australia.
Currently documents for review include:
Constitution Reform Recommendations
Membership Bylaw and Procedure
Code of Ethical Practice
Standards of Practice