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

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Many of you will be aware of how I have raised concerns in the BDJ (http://tiny.cc/WDconcerns ), how the BDA has asked for referral of HTM01-05 to NICE, but this is constantly blocked by the DH ( http://tiny.cc/DHblocksNICE ) and how even Microbiologist patients have raised concerns publically too (http://tiny.cc/CrassAdvice )

So some 3 months after the BDA asked to see the evidence HTM 01-05 was based upon, in December 2009 the DH produced some 90+ references to justify imposing the HTM 01-05 full document upon the Dental Profession.

The first thing that struck me about this list of “references”, was that the minority of these were actual published peer-reviewed scientific articles, with the majority being Man-made rules and regulations. Indeed it seemed to be mainly past British Standards (BS) rules, where future BS standards or even EU rules over-ride these in practice , or even more HTM directives were quoted which all referenced each other with other man-made rules and directives and DH policy papers etc, with VERY LITTLE robust scientific evidence underpinning any of it frankly.

So in a nutshell, some two thirds of what provided as “evidence” for change were mainly committee-created rules-based documents which could easily be superceded by further man-made rules at any time, without impacting on any scientific evidence already out there, because they were not dependent on the science.

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Dental Elf

26 March 2026

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