PHB 40
Bil Iechyd y Cyhoedd (Cymru)
Public Health (Wales) Bill
Ymateb gan: Cymdeithas Siartredig Ffisiotherapi
Response from: Chartered Society of Physiotherapy


CSP Wales Office

1 Cathedral Road

Cardiff CF11 9SD

029 2038 2429

Dr Dai Lloyd AM, Chair

Health Social Care and Sport Committee

Cardiff Bay


CF99 1NA


16th of December 2016


Dear Chair and Committee Members




In response to the call by the Health, Social Care and Sport Committee for written evidence on the general principles of the Public Health (Wales) Bill, the Chartered Society of Physiotherapy (CSP) in Wales is pleased to make a written contribution.


  1. The CSP has one key issue to which we would like to draw the Committee’s attention relating to ‘Part 3 - Special Procedures’.  In particular, this relates to exemptions from a requirement to be licensed for the specific practice of acupuncture. The legislation, as drafted, currently requires additional powers, by way of regulation, for those professions regulated by the Health Care Professions Council (HCPC).


  1. The CSP understands fully the reasons for proposals to introduce changes that provide for the creation of a mandatory licensing scheme for practitioners and businesses carrying out ‘special procedures’ – namely acupuncture, body piercing, electrolysis and tattooing.


  1. Acupuncture is within the scope of physiotherapy practice and physiotherapists are already registered and regulated by the HCPC so do not need to be dual registered with the special procedures register.


  1. The question raised by the CSP is why those professions regulated by the HCPC should require a separate regulation within the Public Health (Wales) Bill – as found at section 57 (3) – to provide for exemption and cannot be treated in exactly the same way as other professions that are regulated by, for example, the General Medical Council (GMC), the General Osteopathic Council or the Nursing and Midwifery Council (NMC)?


  1. Section 57 of the Public Health (Wales) Bill deals with exempted individuals.


Section 57(2) identifies that professions regulated by a body mentioned in paragraphs (a) to (ga) of section 25(3) of the National Health Service Reform and Health Care Professions Act 2002 (c.17) are exempt. Reviewing this piece of UK legislation therefore confirms that there is exemption for doctors, dentists, optometrists, osteopaths, chiropractors, pharmacists, nurses and midwives.


  1. Paragraph (gb) of the National Health Service Reform and Health Care Professions Act 2002 (c.17) refers to the Health and Care Professions Council yet this is not included in section 57(2) of the Public Health (Wales) Bill.  Whilst the CSP acknowledges there is a wide range of professions regulated by the HCPC it would be expected that professions regulated by this body would not be undertaking procedures that were not within their scope of practice and so those regulated by HCPC should be treated in just the same way as those regulated by the GMC or NMC for example.


  1. The profession is hopeful that an amendment can be made to include HCPC professions within section 57(2) of the Public Health (Wales) Bill and hope to see this as a recommendation made by the Health Social Care and Sport Committee in its report at the end of Stage 1.


If you require any further information from the professional body please do not hesitate to get in touch.


Yours sincerely

Philippa Ford MBE MCSP

CSP Policy & Public Affairs Manager for Wales




In association with:

Chartered Society of Physiotherapy Welsh Board

The Welsh Physiotherapy Leaders Advisory Group



About the CSP and Physiotherapy


The Chartered Society of Physiotherapy is the professional, educational and trade union body for the UK’s 54,500 chartered physiotherapists, physiotherapy students and support workers.  The CSP represents 2,300 members in Wales.


Physiotherapists use manual therapy, therapeutic exercise and rehabilitative approaches to restore, maintain and improve movement and activity.  Physiotherapists and their teams work with a wide range of population groups (including children, those of working age and older people); across sectors; and in hospital, community and workplace settings.  Physiotherapists facilitate early intervention, support self management and promote independence, helping to prevent episodes of ill health and disability developing into chronic conditions.


Physiotherapy delivers high quality, innovative services in accessible, responsive and timely ways.  It is founded on an increasingly strong evidence base, an evolving scope of practice, clinical leadership and person centred professionalism.  As an adaptable, engaged workforce, physiotherapy teams have the skills to address healthcare priorities, meet individual needs and to develop and deliver services in clinically and cost effective ways.  With a focus on quality and productivity, physiotherapy puts meeting patient and population needs, optimising clinical outcomes and the patient experience at the centre of all it does.