WHEN "WEIGHT-LOSS INJECTIONS" GO WRONG IN A SALON/SPA

Written by Melissa Eales

Consider the following scenario. A beauty therapist at a busy salon began offering weight-loss drug injections to clients, motivated by the growing popularity of such treatments on social media, where posts promoted the procedure as “just a quick shot” that would leave clients “feeling lighter in days.” Two clients agreed to try the treatment. Within weeks, one developed a painful infection at the injection site, while the other experienced dizziness and required medical attention at a clinic. The salon owner was left contending with distressed clients, a patient receiving ongoing medical care, and a serious legal crisis.

This type of incident is not isolated. Across South Africa, unregistered weight-loss injections — including GLP-1 agonists such as semaglutide (commonly known by brand names such as Ozempic and Wegovy) and fat-dissolving injectables — are increasingly being offered informally in salons and spas by individuals without medical qualifications. The consequences can be significant: for the therapist, for the staff members involved, and for the salon owner.

This article is intended for salon/spa owners and managers. It is important to understand that, in South Africa, it is unlawful for any beauty therapist or beauty practitioner — regardless of their level of qualification — to administer any substance by injection. Permitting such practices on salon premises may expose the owner and the business to criminal prosecution, civil liability, regulatory action, and significant financial and reputational harm.

Understanding the Beauty Industry: Not All Qualifications Are Equal

One of the most common misconceptions in the industry is that a higher beauty qualification somehow extends into medical territory. It does not. The South African Association of Health and Skincare Professionals (SAAHSP), in consultation with the Aesthetics and Anti-Ageing Medicine Society of South Africa (AAMSSA), has published clear scope-of-practice guidelines for the various levels of beauty industry qualifications. Understanding these boundaries is essential for every salon/spa owner and manager.

The table below sets out basically each professional category, what they are trained and permitted to do, and critically what falls outside their lawful scope.

Qualification	Training Duration	What They Can Do	What They CANNOT Do	Regulatory Body
Nail Technician	Varies (qualified, certified, and unqualified)	Manicures, pedicures, nail extensions, nail art	Any skin or body treatments; any injection of any kind	South African Association of Health and Skincare Professionals (SAAHSP)
Beauty Therapist	2-year formal qualification	Facials, waxing, massages, manicures, and non-medical beauty treatments	Any procedure requiring a medical qualification; no injectables whatsoever	SAAHSP
Somatologist	3-year diploma or 4-year degree	Advanced skin & body treatments, laser/IPL, skin peels, microneedling, photo rejuvenation (under appropriate supervision)	Prescribing or administering any medication; no injectables of any kind	SAAHSP
Advanced Aesthetic Therapist / Dermal Aesthetics	4-year Advanced Diploma in Dermal Aesthetics	Advanced non-invasive aesthetics alongside a doctor/dermatologist, assisting in aesthetic practice settings	Still cannot administer any injectables independently. Injections remain illegal regardless of qualification level	SAAHSP, and works under and with a medical practitioner
Medical Doctor / Dentist	MBBS/MBBCh or BDS degree + postgraduate aesthetic training	All of the above, PLUS botulinum toxin, dermal fillers, weight-loss injectables, PDO threads, IV therapy, and all scheduled medicines	N/A	Health Professions Council of South Africa (HPCSA)
Registered Nurse	Nursing degree or diploma	Certain scheduled medicines under a doctor's prescription and within the approved scope	Cannot administer cosmetic or weight-loss injectables independently in SA	SANC (South African Nursing Council)

A key point worth emphasising: even the most advanced beauty or aesthetics diploma does not grant any legal authority to inject. As Dr Debbie Norval, Past President of AAMSSA, states clearly in the AAMSSA Bulletin “Aesthetic Appointment Journal, November 2023: beauty therapists, somatologists, and advanced aesthetic therapists are not legally permitted to perform injections of any kind in South Africa. This includes fat-dissolving injections, botulinum toxin, dermal fillers, PDO threads, and IV therapy. Injecting falls entirely outside their scope of practice — it is both unsafe and unlawful.

Furthermore, there is currently no statutory regulatory body governing the beauty profession in South Africa. Unlike doctors and dentists, who are registered with and regulated by the Health Professions Council of South Africa (HPCSA), beauty therapists and somatologists operate without formal statutory oversight; however, the industry does have a professional body (SAAHSP) that ensures that beauty therapists, somatologists, and technicians operate within their scope through standard operating procedures and continuous professional development. In the absence of statutory regulation, it makes public education and salon/spa owner vigilance even more critical.

The Law: Why Injecting Is a Criminal Matter, Not Just a Policy Issue

Administering anything by needle, whether a weight-loss drug, a vitamin shot, or a fat-dissolving compound, is classified as a medical act. Only registered health professionals are legally permitted to perform medical acts. The following legislation makes this unambiguous.

Medicines and Related Substances Act 101 of 1965

No person may sell or administer any scheduled substance unless they are a medical practitioner, dentist, registered nurse, or other health professional registered under the Health Professions Act. Weight-loss injectables such as semaglutide are classified as Schedule 4 or 5 medicines. A beauty therapist, somatologist, or advanced aesthetic therapist has no legal authority to advise, handle, supply, or administer these substances.

Health Professions Act 56 of 1974

Only persons registered with the HPCSA in the correct category may perform regulated acts. Administering injections is a regulated act. Performing it without HPCSA registration is a criminal offence, not just a workplace misconduct issue.

Occupational Health and Safety Act 85 of 1993 (OHSA)

Employers are legally obliged to provide a safe working environment under Section 8 of the OHSA. Permitting injections to be administered on salon/spa premises constitutes a breach of this obligation. The consequences may include fines and potential imprisonment, even where the employer was unaware that injections were taking place.

This last point deserves particular emphasis: as the salon/spa owner or manager, you carry legal responsibility for what happens on your premises.

The Risks: Why a Salon/Spa Is Never a Safe Environment for Injections

Beyond the legal framework, there are significant practical and medical risks to consider when injections are administered in a salon/spa environment.

• Infection risk: Salons/Spas are not sterile clinical environments. Needle use can cause bacterial infections, abscesses, or the transmission of bloodborne pathogens.

• Incorrect dosage: Untrained individuals may administer too much or too little of a substance, leading to overdose, allergic reactions, or treatment failure.

• Nerve and tissue damage: Injecting into the wrong tissue layer can cause necrosis (skin death), nerve damage, or permanent scarring.

• Counterfeit or unregistered drugs: Many weight-loss drugs offered informally are counterfeit, contain harmful substances, or have been stored incorrectly.

• No medical oversight: There is no doctor assessing medical history, allergies, or contraindications. This creates a risk of life-threatening reactions.

• Civil liability for the salon/spa: If a client or staff member is injured, the salon/spa owner can be sued for damages under negligence and OHSA violations.

• Consumer confusion: When medical procedures are offered in a salon/spa setting, clients may not understand who bears responsibility or what risks they are accepting.

The Legal Consequences: What Can Be Charged

Where a salon/spa owner or employee is found to have injected clients or any person, the following offences can be charged:

Offence	Law	Who Is at Risk	Potential Consequence
Administering a scheduled substance without authorisation	Medicines and Related Substances Act 101 of 1965	The employee who injected	Criminal prosecution, fines, imprisonment
Practising as a health professional without registration	Health Professions Act 56 of 1974	The employee, the supervising doctor (if applicable)	Criminal offence; possible imprisonment; medical licence revocation
Possession/supply of unregistered medicines	Medicines Act + SAHPRA enforcement	Supplier and possessor	SAHPRA seizure and prosecution
Wilful endangerment of colleagues	Labour Relations Act (Schedule 8)	The employee	Summary dismissal for first offence
Breach of occupational health and safety obligations	OHSA Section 8	The salon/spa owner/employer	Fines, criminal prosecution, imprisonment

It is also important to note the medicolegal risk for any medical doctor who may be associated with the salon/spa. According to AAMSSA guidance, a supervising doctor who permitted or failed to prevent a therapist from performing injectable procedures could face charges of aiding and abetting the unauthorised practice of medicine, with potential consequences including disciplinary action, fines, or revocation of their medical licence.

What Must You Do as a Salon/Spa Owner?

Your obligations are clear, and acting on them now will protect your business, your staff, and your clients.

• Know your team’s qualifications: Understand exactly what each staff member is qualified and permitted to do. A certificate in somatology or advanced aesthetics does not authorise injections.

• Have a clear workplace policy: Your salon/spa’s policies must explicitly prohibit the administration of any injectables on the premises, by anyone, at any time.

• Act immediately if you discover a violation: Administering injections in a salon/spa constitutes a serious misconduct offence under the Labour Relations Act. A properly conducted disciplinary process may result in dismissal on the first offence.

• Inform your clients: If your salon/spa has been offering or allowing injectable treatments, you have a duty to notify affected clients and to cease the practice immediately.

• Refer injectable treatments appropriately: If clients are asking for weight-loss or aesthetic injectable treatments, refer them to a registered medical doctor or aesthetic medicine practitioner. A useful resource is www.aestheticdoctors.co.za, which provides a directory of HPCSA-registered practitioners in South Africa.

The Bottom Line

The growing popularity of injectable medicines and aesthetic treatments has created a grey market that is finding its way into salons/spas in South Africa. For salon/spa owners, the law, rules, and regulations are unambiguous: These procedures do not belong in a salon/spa environment, regardless of who is offering them or how experienced they appear to be, unless they are Registered and Trained Medical Practitioners.

A beauty qualification at any level is not a medical qualification. The line between what your staff can and cannot do is set by law, rules, regulations, and their qualification scope, not by confidence, experience, or the desire to offer more services.