Booking a Botox injection in Canada can be easier than securing an appointment with a family doctor.
In Kingston, residents put up camping chairs in line for a chance to get a family doctor, while medical spas advertise same-day cosmetic treatments. The imbalance in accessibility has become routine enough to draw little scrutiny—until something goes very wrong.
In November 2020, days before her 39th birthday, a woman died after undergoing microneedling at an Oakville beauty clinic, where a prescription numbing cream containing lidocaine—a local anesthetic medicine—was applied over large areas of her body.
She suffered a medical emergency and later died in hospital, with a coroner determining the cause of death to be lidocaine toxicity. The case, documented in police records, a coroner’s report, and a civil lawsuit filed by the woman’s family, was later examined by the Toronto Star.
According to reporting, no physician was present during the procedure, and the clinic’s medical director wasn’t involved in the treatment, only learning of the death the following day. The lawsuit alleges negligence against the clinic, its owner, the esthetician, and the medical director; all parties deny wrongdoing, and the allegations haven’t been proven.
While the case remains before the courts, it’s raised serious questions about how cosmetic medicine is regulated in Ontario, and about what patients reasonably assume when a cosmetic procedure is described as medical.
Medical spas, sometimes called medispas, are commercial clinics that offer cosmetic and aesthetic procedures—such as injections, laser treatments, and skin therapies. They make use of prescription drugs, invasive techniques, and medical devices, yet often resemble retail spas more than medical clinics. Ontario permits physicians to delegate certain controlled medical acts, including cosmetic injections and the use of anesthetics, to non-physicians.
There’s no consistent requirement that the delegating physician be physically present. Although this regulation may be intended to provide flexibility, it has enabled arrangements in which clinicians oversee multiple clinics with limited involvement in day-to-day patient care.
In a consultation note dated March 31, 2025, and addressed to the College of Physicians and Surgeons of Ontario (CPSO), one physician warned that such “medical directors” are too often absent from, or unaware of, the practices they are responsible for overseeing. Without consistent standards of care or meaningful assessments of practitioner competence, the physician wrote, patients are exposed to avoidable risks.
These concerns are substantiated. Procedures commonly performed in these settings have established medical risks. Improper administration of botulinum toxin (or Botox), for example, can result in paralysis and, in rare cases, death. Lidocaine toxicity is also a recognized medical emergency, with risk increasing when anesthetics are applied over large surface areas or to compromised skin, such as during microneedling. Symptoms can escalate quickly, progressing from dizziness to seizures and serious cardiac complications.
Despite these risks, cosmetic procedures are often advertised as routine self-care with marketing language that downplays their medical complexity and potential risks. A 2024 study found that patients seeking cosmetic procedures may be more likely to underestimate the risks involved. The presence of a physician’s name on promotional materials can further reinforce a sense of safety, even when that physician isn’t directly involved in providing care.
The growth of medispas also reflects pressures within the healthcare system. Canada’s shortage of family doctors has left millions without access to primary care. At the same time, cosmetic medicine offers clinicians predictable hours and higher earnings per patient than publicly funded practice. While family physicians manage complex and chronic conditions under significant administrative constraints, cosmetic clinics can generate substantial revenue in a relatively short time. The financial incentive is clear.
Regulatory bodies, such as the CPSO, have started to respond. The CPSO has held consultations on its delegation and supervision policies, with its most recent update released in 2025. The question isn’t whether cosmetic medicine should exist, but whether procedures involving prescription drugs and invasive techniques should operate under different standards than other medical care.
Tags
Cosmetic medicine, Health regulation, Patient safety
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