Public authorities like the NHS often take a beating from energetic health journalists during the annual Christmas news doldrums. Why? Large, complex organisations always have problems, but are less likely to fire off menacing lawyers’ letters than dodgy banks.

Was the 2011-12 holiday period worse than usual? Neglect of the elderly and those with learning difficulties and problems with drink, drugs and obesity all loomed large. With worries over patient records and (of course) the cuts, it felt worse to me. What caught my eye? Two more specific issues of transparency and accountability.

The first can easily (I think) be resolved. Junior health minister Lord Howe was accused in The Observer by the anti-smoking lobby of taking secret briefings from the tobacco industry during the passage of Labour’s 2009 bill to restrict the display of cigarettes and ads in shops, one where small shops were given extra time to adapt to potential loss.

Not guilty, I’d say. Politicians should always listen to both sides, even the perceived “bad guys”, in a debate. I concede the tobacco barons can be awful, but they are also heavily regulated. The Lansley regime has not eased the rules. Did I say “heavily regulated”? Clearly this is far from the case in the cosmetic surgery business, as the PIP breast implant scandal highlights. “Cosmetic injections the ‘next disaster’”, screamed Tuesday’s Times, keen to point out that Botox is a medicine which need not be injected by a doctor.

PIP implants were made in an under-inspected French factory, but licensed for the EU’s single market in Germany, nodded through by the predecessor of Britain’s Medicines and Healthcare products Regulatory Agency (MHRA), all unaware that PIP had substituted a cheaper product as long ago as 2001. As so often, US regulators were more robust.

Oh dear, I hadn’t realised what a mess this is, the cosmetic “Wild West” according to one senior plastic surgeon. Surgeons say they were raising doubts (ignored until a tip-off last year) in 2006. It’s primarily a private sector problem, of course; the NHS does reconstructive breast surgery, on a scale tiny compared with the cosmetic branch. But (as usual) the NHS picks up the debris.

Earlier this week both the MHRA and DH websites still carried “keep calm/no evidence of cancer” statements on PIP, 10 days old. Was this a Christmas media scare, I wondered. No. Andrew Lansley’s officials tell me that as soon as the secretary of state was told that the cosmetic group, Transform, was saying its rupture rate on PIP implants was 7 per cent, not 1 per cent or less, he set up that urgent review. Quite right too.

The plastic surgeons are saying all such implants should be replaced anyway (they would). In opposition Labour’s Andy Burnham is saying the private sector should pick up the bill for its own errors (he would). They’re probably both right, although Labour scrapped the old, inadequate register of cosmetic surgery in 2004 and proper risk analysis – not media-driven panic – should dictate policy.

Part of the problem in 2012 is the lack of a proper paper trail. Suppliers of such a sensitive product as a breast implant (or Botox?) should be responsible for the products they use (what about a barcode?) and for keeping proper records as part of the service for which they charge big bucks. Stephen Dorrell, ex-health secretary, now chair of the Commons health committee, certainly thinks so.

By now Lansley probably does too. In the mid-90s Dorrell was the minister at the heart of the BSE (“mad cow”) trauma. Politicians must rely on experts. “Quality advice, publicly given so it can be challenged” is his maxim.