The GDC has pointed out that while it “does not support the use of these procedures by GDC registrants outside the perioral area”, this does not mean that registrants cannot use them, but rather that there must be a clear separation between their use and any practice of dentistry by the registrant. With many practices having made these procedures a central part of their healthcare practice, this “separation” may end up being totally artificial, difficult and costly to achieve, and against the best interests and wishes of patients.

“Patients have a right to choose what procedure(s) they wish to undergo, when and from whom. If they have built up a relationship of trust with a dental registrant, perhaps over many years, this is a material fact that the patient has every right to place in the balance of their consent decision when undertaking these procedures. If they know full well that their chosen clinician is a dentist, what purpose does the requirement for ‘separation’ achieve? And is it really in the public interest, when they are choosing from whom to seek these services, that the information (ie. that someone is a registered dental professional) should be denied to them as a matter of GDC policy? This runs directly contrary to the GDC’s own guidance in Principles of Patient Consent.”

“It is also a fact that some oral and maxillofacial surgeons use botox for cosmetic purposes, in association with surgery for trauma, pathology and also in relation to orthognathic surgery. Special needs dentists might also use botox, albeit mostly for non-cosmetic purposes in that case.

“We will be making our concerns known to the GDC, which is due to consider the Scope of Practice issue again when it meets in September, and approve a more detailed guidance document thereafter. ”

Following the recent ‘Scope of Practice’ consultation, the GDC decided at its June 2008 session that the provision of non-surgical cosmetic procedures such as botox and dermal fillers, away from what the GDC variously describes as “the perioral area” or “immediate perioral area”, does not constitute the practice of dentistry.

The Council has also expressed the view that certain ‘alternative / complementary therapies’ that are not provided in conjunction with, or linked to, a patient’s dental treatment must be provided separately to a registrant’s practice of dentistry. These decisions were reflected in a Statement issued by the GDC in July 2008.