GDPUK.com Opinions:: Tony Kilcoyne: a critique of HTM 01-05

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Tony Kilcoyne is a prosthodontic specialist, a dental educator, and an elected member of the GDC. He runs a practice in Haworth in Bronte country, West Yorkshire. He is very well known to GDPUK readers.

Dr. Kilcoyne has been a long term, highly vocal critic of the Health Technical Memorandum that has so raised the ire of the English dental profession.

In this article, he carefully unpicks the unscientific nature of this document.


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Cross-infection control is important in everything we do when treating and caring for patients in our Practices or Clinics. Furthermore, we constantly strive for improvements and changes in the way we work and enthusiastically adopt such changes when they have been shown to be both better and more effective than what we do now.

So why all the fuss about HTM 01-05 changes being imposed now?

Well Dentistry is also littered with many failed and experimental changes which arrived on the scene with much hype and promise, but when actually put to the test of real-life Practice were found to disadvantage patients rather than advantage them, were found to have little or no Evidence-Base that supported them more than some existing alternative methods, no proper Impact-Assessments had been done or followed through and in some cases, an embarrassing reversal to more proven/established methods occurred in our patients’ interest. But what happens when the changes proposed are SO far-reaching, that they involve vast sums of money, time, reorganization etc, that they become irreversible by virtue of changing how you do everything?

A recent warning of how such drastic changes can backfire was forcing Surgeons to use disposable surgical equipment to reduce possible prion transmission risks between patients. This Sponsored idea from the DH didn’t go through proper development, testing and impact analysis protocols, but was unilaterally imposed, sadly then found to cause an unacceptable level of additional complications and patient deaths that could have been avoided, so this system had to be abandoned and a return to reusable Surgical instruments occurred.

Do we want to see the same happen to Dentistry via HTM 01-05, which will be potentially causing Practices, PCTs and the DH to divert many £millions away from frontline patient care, just as we are entering a national recession and facing public-sector cuts too. When HTM 01-05 doesn’t have the clear support of the published scientific evidence base, no Impact assessment has been done/published, no third-party independent validation and when even those who were consulted during the writing of HTM01-05, have since publically asked for referral of HTM 01-05 guidelines to NICE, then one REALLY has to have concerns about how HTM 01-05 is being forced upon us all.

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Dental Elf

26 March 2026

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