I am a registered dental technician and dental prosthetist (or clinical dental ... As
you know I currently chair the Dental Technician's Registration Board of ...
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,. ' Expanded Submission from 08.02.2013 Mr Trevor Ruthenberg MP Chair Health and Community Services Committee
[email protected] .au
Dear Mr Ruthenberg Dental Technicians Board of Queensland submission to the Health and Community Services Committee regarding its inquiries into the Health Practitioner and Other
Legislation Amendment Bill 2012 The Dental Technicians Board of Queensland is grateful for the opportunity to comment on the Health Practitioner and Other Legislation Amendment Bi/12012, which was introduced in the Legislative Assembly on 27· November, 2012 by the Hon.U Springborg MP, Minister for Health, and was referred to your Committee on the same date. The Board notes that the Bill is intended to give effect to the government's decision to abolish state registration of dental technicians and speech pathologists, and all consequences of that decision. As such, the Bill would appear to meet the broad policy objectives of the government ie the repeal of the legislative scheme, the distribution of the assets and liabilities of the two Boards and the Office of Health Practitioner Registration Boards, and provisions for other consequential and transitional matters. In this respect my Board has not identified any issues with the drafting of the Bill. My board is convinced however that it is in the public interest for dental technology to continue as a regulated profession. While this should preferably be within the framework of the National Scheme, until this .is achieved continuing regulation under State legislation is desirable and most appropriate. Thank you for the opportunity to address the Health and Community Services Committee today. I am a registered dental technician and dental prosthetist (or clinical dental technician) with a long standing commitment to high standards of practice and training in both professions. As you know I currently chair the Dental Technician's Registration Board of Queensland and I am a member of the Queensland Registration and Notifications Committee of the Dental Board of Australia. I am currently employed as Senior Lecturer in Prosthetics and Business Development Manager of the School of Dentistry and Oral Health at Griffith University.
My comments are directed to continuing registration of Dental Technicians. Statements in favour of retaining registration : In September 1996, Mike Horan, Minister for Health released the Qld review of medical and health practitioners registration legislation, Draft Policy Paper. The paper stated that health professionals are regulated in order to protect the community and promote quality health care standards (Draft Policy Paper 1996)
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In the Summary of Recommendations the following statements were made: Greater pufl:tl~: protection will be achieved by: • Enhancing the boards' ability to ensure registrants meet appropriate standards; • The effective regulation of harmful practices; • The'establishment of new systems for the discipline of registrants and management oftmpaired practitioners. The Policy ~!3per promoted registration as a way of ensuring more thorough assessment of applications.for registration and proposed mechanisms to ensure the ongoing competence of
practitione~, for example, encouragement of continuing professional education; recency of practice; scr.utiny of applications for renewal of registration. ···{· .
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In our view this was a sound basis for a registration framework and it continues to be the view of the majority of dental ~echnicians in Queensland as evidenced by the submissions from the A1:1s,tralian Dental Prosthetists Association Queensland and the Oral Health Professionals Association.
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Dental tec~~ology has been a regulated profession in Queensland since 1988, initially through the,Oental Board and under a separate board since 1992. Dental tech nicians lobbied strongly fdf.. many years to ·achieve registration and recognized professional status. Registration for dental technicians and prosthetists was supported by both Liberal/National Party and Labor governments. .
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A number of our .current registr-ants (20%'-25%} live. and work interstate, have no intention to live: or worlbn Queensland, tiut have maintained their registration. They are outside t he jurisdiction qftlhe Queensland Board and receive no apparent benefit from this Board except formal registration. Their willingness to pay a registration fee for Queensland registration when it is not required in their home state indicates the value that they place on being a registered practitioner. Three other Australian jurisdictions required. registration for dental technicians prior to the implementati"on of the. first phase of the National Scheme in 2010. These were New South Wales, South Australia and the ACT. This represented at the time about 80% of Dental Technicians practising in Australia. The dental technology profession was not identified for accession to t he National Scheme, either with the initial implementation on 1 July 2010 or in the extended scheme which was implemented on 1 July 2012. Although a partially regulated profession, the profession consistently maintained there was a compelling case for entering the National Scheme in both phases of its implementation. There was a view that the registration of DT's was anti-competitive and deregistration of dental technicians would reduce costs in dentistry. There is no evidence that deregistration of dental technicians has had any impact on the overall cost of dentistry to the public which has not changed and still increases on a CPl basis every year. Under the National Scheme a number of allied dental groups are now registered by the Dental Board of Australia. These are: dental therapists, dental hygienists, dental prosthetists and oral health therapists. Our close professional colleagues, the dental prosthetists, of course must also be dental technicians, and so the reason for distinction between these two groups in eligibility for national regulation is unclear.
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The regulation of the profession over the past decades has arguably resulted in significant improvements in the ethics, art and science of dental technology. Entry and training standards have become consistent and among the world's best as a result. Regulation has clearly contributed to safe, high quality professional oral health care for the public. As noted in the submission from Professor Newell Johnson, Professor of Dental Research, Griffith Health Institute, Queensland has led the way in the development and delivery of courses for dental technicians and prosthetists. Professor Johnson noted that dental prosthetists must first be qualified as dental technicians. There is no educational program for the education of Dental Prosthetists (Clinical Dental Technicians) in Australia that does not rely on the fact that the candidates must first of all be qualified Dental Technicians. The fact that dental prosthetists are dental technicians first has possibly contributed to the success of the clinical dental technicians profession in Australia. The system produces a very well educated professional who has a wide range of skills in the oral health field. Dental technicians are registered in the UK, Sweden, Germany, Switzerland, some states in the US and Canada. In the UK the General Dental Council registers Dental Assistants in addition to the oral health professionals already named. The General Dental Council in the UK has recently brought forward a National registration scheme for all Oral Health professions including dental technicians and dental assistants as they consider both professions have excellent training programs and are obviously part of the oral health team. The main reasons for registration put forward for oral health professionals by the General Dental Council were: • Uphold and follow standards Because of the nature of the work carried out by oral health professionals it is very important to maintain and advance the standards for practice and education. • Maintain Continual Professional Development Maintenance of continuing education and professional development is crucial to any profession and without registration almost impossible. • Understand your professional indemnity responsibilities Unregistered professionals have difficulty in purchasing insurance covering public liability, product liability, and professional indemnity. The Queensland Board has in the past had complaints about dental technicians who have not been compliant and has dealt with these complaints via the process outlined in the governing legislation. The Queensland Board has been very vigilant and insisted on quality education programs and cooperated with the other states and the Commonwealth Government in maintaining and advancing the educational programs available within Australia. The role of the dental technician as a member of the oral health team:
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In order to provide a better understanding of the role of the dental technician it may be helpful to present an overview of the scope of practice and the practice environment of the members of the profession. A dental technician, on prescription of a dentist, medical practitioner or clinical dental technician makes any prosthesis or appliance for the head and neck. This could consist of: •
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Artificial teeth such as complete dentures, partial dentures, crowns and bridges and implant supported dentures in valious materials such as acrylics, composites, biocompatible metallic alloys, and biocompatible ceramics; Removable orthodontic appliances consisting of springs and retainers in acrylic bases for the movement of teeth. The orthodontic appliances could be either intraoral or extra oral depending on the complexity of the case. Mouth guards to protect against sports injuries; Maxillofacial appliances such as artificial eyes, ears, and facial prostheses that may be required after treatment by a Maxillo-facial surgeon. There has been a noticeable increase in the use of computer-aided design CAD and computer aided manufacture CAM in many branches of medicine and surgery. Dentistry and oral surgery is no exception. A dental technician may be called on to manufacture, with the aid of CAD CAM, a segment of bone for replacement of tissue lost to accident or major surgery or bone augmentation in preparation for implants.
Dental technicians work closely within the oral health group consisting of dentists, dental prosthetists, oral health therapists and oral hygienists. The dental technology profession is in fact the technical side of dentistry. Dental technicians work in a dental laboratory on their own or in small work groups where the various prosthetic appliances are custom made. They might be thought of as artisans who, with a thorough understanding of dental materials science and anatomy apply a unique set of skills to fabricate the form, colour and function of individual teeth or maxillofacial prostheses for a patient. These appliances must be anatomically correct and bio-compatible to ensure the safety of the patient. The fact that the product can affect the health and appearance of a person demands a high level of responsibility and accuracy. Technology advances, particularly in the area of 3D and CAD CAM have led to an influx of work from International laboratories. Many appliances are imported from countries where standards of manufacture are highly variable and where there is no oversight of the materials used to guarantee recognised standards of hygiene or biocompatibility such as the standards required by the Therapeutic Goods Administration in Australia or Food and Drug Administration in the US. When an appliance is placed in a patient's mouth the responsibility for the safety falls to the person who inserts that appliance whether it is removable or fixed. A removable appliance is one that the patient is able to remove unaided by any practitioner. A fixed appliance is one that can only be removed by a dental practitioner (Dentist) in this instance. Before the practitioner inserts the appliance they must be sure of its quality and take into account biocompatibility, strength, functionality and aesthetics. The only aspect of the quality assurance process that is impossible to check is its biocompatibility.
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The practitioner who inserts that appliance, fixed or removable is the person legally responsible for the appliance. In most instances this is the Dentist or Dental Prosthetist. No one can tell the difference between a good appliance or a bad appliance without a complete analysis of the product which would lead to the destruction of that appliance. There is no visual test available to determine if an appliance placed in to a patient's mouth is biocompatible or not.
The practitioner therefore must have ultimate faith in the dental technician who has manufactured the product. If that practitioner is overseas or an unregistered dental technician in Australia, then there is no jurisdiction other than court action to provide any recourse for the practitioner or the patient in the event of an injury to a patient or failure of the appliance . As there is no insurance available for unregistered dental technicians, then court action is probably not worth the effort. This places an unfair burden on dental practitioners who are required by law to be registered . Unless there is a threat of Board action to deregister or other punitive action the dental technician will have no obligation to obtain recognized qualifications or to operate to any profession.al standards. In summary, the Board believes that the public interest would be better served if dental technology were to remain as a regulated profession in Queensland until the profession is admitted to registration under the national scheme. I trust the above comments will add to the committee's knowledge and understanding of these important issues which are relevant to the committee's inquiry, and assist it in its deliberations. Should you require any further clarification, I would be pleased to assist. Yours sincerely
John Mackay Chairperson
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