THE INSIDE VIEW

There was a breakfast meeting of the British Dental Bleaching Society (BDBS) hosted by Linda Greenwall, on Friday 17th June 2011 to discuss the current crisis in tooth whitening. There is some good news, with perhaps more news on the horizon.

Mike Volk of Dental Directory presented his recent email from Trading Standards, which was the result of three months of negotiation. He announced that from today he has started selling in-surgery bleaching kits. Even though his Trading Standards are in Essex, he has been told by his lawyers that he can sell in-surgery whitening materials across the UK. Mike said “one important aspect is that Trading Standards have stated in the email that tooth whitening is practise of dentistry and should only be provided by dentists.”

He also said that his legal team is continuing to work with Trading Standards about home tooth whitening. You can. read the latest letter to dentists from Mike Volk here.

But recently the MHRA has become involved (jumped on the bandwagon?) because many whitening products currently for sale in the UK are classed as medical devices (CE mark) and they should all be classified as cosmetic products. Evidently the MHRA has told some manufacturers to stop supplying their products to the distributers, because of the incorrect labelling. So although Dental Directory can start selling some bleaching products, they may still have difficulty with some supplies.

Sir Paul Beresford informed the meeting that he has managed to get a debate about this issue in the House in the near future.

Barry Cockcroft, the Chief Dental Officer said “tooth bleaching is non-invasive, and not damaging if done by a registrant. Patients have the right to choose, based on informed consent. Good oral health and good appearance are now seen as the norm. Other more invasive treatments such a crown and bridgework, have a much higher likelihood of complications.”

He joked that “you can’t un-drill teeth!” He said that both he and the Department are completely agreement with the GDC that registrants should be the only ones to carry out tooth whitening, adding that should non-registrants provide it, there is a massive risk to patients.

Barry went on to explain that changes to the European Cosmetic regulations are proposed but blocked in Brussels and that even though the Essex Trading standards have written to Dental Directory, it still could happen that a dentist could be prosecuted by Trading Standards in another area. He said that if a dentist was prosecuted, he would like to go and speak on behalf of the dentist and the patients.

The CDO held a meeting yesterday with the MHRA and The Department of Business Innovation and Skills (Trading Standards is one of their partners) about a proposed amendment to be submitted to the to the Commission to the EU Parliament within the next few weeks. This is very promising, because previously the proposals have been submitted to the Cosmetics Directive, which is a very slow process, whereas with the Commission to the EU Parliament, there could be a resolution much more quickly.

Barry explained that for the first time he is confident that something will happen.

My fear is that if dentist cannot use hydrogen peroxide products, patients will use therapists who may use chlorine dioxide or other harmful products. Whilst there is a glimmer of sanity in the recent Essex Trading Standards email, home tooth whitening is still ‘off the menu’ for the time being. CODE is planning to release the latest advice on tooth whitening to members early next week, after consultation with the BDBS.

I wonder why find it so stresfull to fill in forms? There’s something scary about putting information on a document and signing it. Even harmless forms such as the garden centre discount club can give you a mild pang as you complete it and think about wasted trees from junk mail or the email marketing campaign heading your way. If the census lands on your doorstep, you know you should fill it out with personal information, but you worry that the Government is about as good at keeping data secure as it is at inventing dental contracts!

The exponential curve of stress levels on the y axis versus forms on the x axis, goes pretty high with GDC fitness to practise documentation, but now we have the Care Quality Commission application form, breaking all records and taking first place in the nightmare  forms competition.

One reason might due to the fact that it is illegal to make a misleading statement, for example saying that you are compliant with one of the outcomes when you are not, another might be that you fear making a technical error could lead to the CQC closing your practice down.

But is a form actually more risky than an email? We send of dozens of emails a day without even thinking about it. An email is a legal document and there have been lawsuits won and lost over them, but we often send electronic mail without a second thought, with poor grammar, slang abbreviations  like IMHO (which means the opposite of course) and flippant comments.

The tendency with emails is to sign them with love, with an X. Whether you are male, female, young or old you may sign emails like ‘X Paul’, ‘XP’ or even ‘XXXXX’ if you are feeling particularly affectionate. Perhaps that’s what stops us from being wary of sending them, if you sign off with love then nothing bad can come of it. This leads me to think that the CQC application form should be signed off with an X, let the CQC know you love them so they will be nice to you, give them a big kiss – perhaps not!

On a more practical note I would like to consider the implication of the CQC application form. It’s new to all of us so we have to look outside of dentistry for some guidance.

CODE Assure consultants come from other areas of compliance such as the FSA and care homes. So I asked Ian Langley, the lead CODE consultant with 30 years experience as a compliance advisor and assessor for his opinion on completing the form, he said: “The application is the start of your file, in which the CQC begins to build risk profile based on what you say and how you say it.  They can take into account whether you send the application on time and the quality of the information in it. This means that right from the beginning a position of compliance and cooperation will put you in good stead, whereas if there is an attitude of reluctance or being under sufferance, this would indicate that you are a higher risk to their standards.”

You can watch a video here on how to complete the form.

Here are some CODE guidelines for completing your application form:

• Use a recognised source for your procedures, policies, risk assessments and audits
• Set up a good clinical governance system
• Carry out some general staff training early on and then set up an annual programme of regular training, that’s how it works in Clinical Governance Made Simple
• Keep all comments on the application form positive and constructive
• Don’t be afraid to say that you are not compliant in an outcome if you are not, but make sure that you are compliant in most of the 16 mentioned on the application form, take the time between application  and inspection to set up compliance for the rest of the 28 outcomes and to thoroughly train the team
• When the CQC asks for something – your answer is YES
• Clinical Governance Made Simple members can find a new FastTrack CQC resource on the members section of the CODE website, at the moment it all about application, later on it will be about training and compliance

CODE Assure can carry out a health-check of compliance for you or even a complete hand-holding service. Next year CODE Assure Accreditation can keep you compliant and award you the new Quality Marque for dentistry.

The average dental practice is 2.5 chairs or about 8 people, occupying 1200 square feet. Yet we are subject to most of the regulations suffered by NHS hospitals employing thousands of people. An emergency resolution at this year’s Conference of Local Dental Committees suggested that dentists should be excluded from those bodies which have to register with the Care Quality Commission (CQC) was passed without dissent. Earlier in the day Conference had had a presentation from a representative of the CQC and there was a lively question and answer session. .

This debate followed a statement by Dental Protection’s Kevin Lewis that regulation of dentistry was ‘out of control’. He called the evidence base for these changes ‘sketchy or non-existent’. Dental Protection has reported an unprecedented demand for its advisory services. This is echoed by CODE who finds that it is increasingly difficult to make a dental practice viable due to the burden of administration.

The CQC is the most pressing regulation for dentists to comply with as from April 1 next year every general dental practice, whether NHS, private or mixed must thew registered with them. Applications start in October this year. According to their website dental services are subject to ‘a range of checks in areas such as professional regulation, NHS performance monitoring and accreditation by private insurance and membership schemes.

This is all in addition to the controls exercised by the primary care trust if you have an NHS contract, including compliance with HTM 01-05. It is also in addition to dentists’ obligation to be on the Dentists Register at the General Dental Council (GDC). This in turn imposes obligations to carry out continuing professional development. The GDC also issues guidance; the most recent being that every patient is entitled to a ‘statement’ of where and by whom their denture or crown was manufactured.

Anger is welling up in the profession at this seemingly endless stream of regulation and controls, with each regulatory body often duplicating others. Lord Colwyn this week raised concerns from dentists on the overregulation of the profession in a debate in the House of Lords. The Conservative Peer and Officer to the All-Party Parliamentary Group for Dentistry asked the Government about the growing burden that changes to professional regulation are placing on general dental practices and the impact on delivering patient care.

In a House of Lords debate, dentist Lord Colwyn said dentists faced ‘mounting challenges in the management of their practices’. He said that any additional layers of governance should be scientifically based and targeted where they are justified and most needed, rather than being applied across the board. Replying the minister Earl Howe said he recognised ‘the fear of overregulation’ that dentists had. But he declined to do anything about it, trusting in assurances he had had from the CQC.

And yet the Government is reviewing all unnecessary regulation across Whitehall, including suspending the vetting regulations aimed at preventing paedophiles from working with children and a look at Health and Safety legislation. It is high time they looked at the over-regulation of the dental profession as well.

CODE helps members to comply with HTM 01-01 with the Infection Prevention Kit and is running a series of seminars this autumn ‘Getting Ready for Care Quality Commission Registration’

Is the IHAS shooting itself in the foot by refusing to let hygienists register for the quality mark. Registration may be off to a rocky start as the consumer launch been delayed from May until mid-July, meaning practitioners have little incentive to sign up. Indeed, a search for London-registered practitioners yields a single result, Freedom Health in Harley Street. So limiting the types of practitioners who can register isn’t doing them any favours.

The reasons for the ban on dental hygienists seems unclear. Hygienists have excellent clinical and cross-infection skills, training in medical emergencies and can administer dental anaesthetic injections, after a short course. In addition, there are established team working skills: hygienists work closely with the dentist, which gives an ideal scenario for skin treatment; and this frees up the dentist for more advanced treatments; and it could offset the high cost of employing hygienists, which is more important than ever given the state of the economy.

It’s not as if there’s a financial risk in registering hygienists to the scheme, as malpractice insurers are more than willing to insure them. Mike Glanville of Hamilton Fraser says, “Three years ago we found that the number of requests for insurance from dental hygienists undertaking Botulinum Toxin and Dermal Fillers was increasing. Following in-depth research into the training and qualifications that hygienists were expected to attain, coupled with our own non-medical research, risk assessments and guidance from respected industry experts, we felt that hygienists demonstrated a level of competence that satisfied our underwriting criteria.”

So does Glanville regret this decision at all? “Three years on, and with the level of complaints from patients treated by dental hygienists remaining on par with other medical professionals offering similar treatments, we are currently considering widening our acceptance criteria further to include dental hygienists undertaking procedures without the supervision and guidance of a dentist, such is our commitment to this sector of the industry.”

CODE will be lobbying the IHAS to accept hygienists to the quality mark registration. Please leave comments to show your support

For more information on courses for dental hygienists, see the seminar section of the CODE website.

Hamilton Fraser Insurance Services can be found here.

Harley Street derma-surgeon, Dr Mario Russo, has launched a new anti-aging development called Stem Self Rejuvenation. The procedure, which has been authorised by the Human Tissue Authority, offers a ‘natural’ approach to anti-aging.

Fat is extracted from the client’s stomach, hips or thighs via manual liposuction, and processed to extract the stem and regenerative cells. These are then injected into areas requiring rejuvenation, including the face, neck and hands. By using the client’s own stem cells, the risk of rejection is removed.

Possible side effects include swelling, bruising and numbness for up to a fortnight. Antibiotics may be prescribed to avoid infection.

Stem Self Rejuvenation helps restore soft-tissue volume, reducing or eliminating wrinkles and correcting mild imperfections. Early clinical experiences suggest the procedure also improves skin tone and texture, and minimises discoloration. The full procedure takes three to four hours and costs £7,500 for the whole face.
For more information you can visit their website.