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of what provided as “evidence” for change were mainly committee-created rules-based documents which could easily be superceded by further man-made rules at any time, without impacting on any scientific evidence already out there, because they were not dependent on the science.

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Waseem Qureshi
is the BDA listening?is it acting robustly? what is its latest response? where is the A12?
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Prof. Andy Bates
Start Writing.
Now they've started work, it's time to start writing letters.

I've written to my (new) MP today, and enclosed a copy of this article.

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Anthony Kilcoyne
New Government - a listening one this time?
Dear All,

I do think with a new Liberal-Conservative Government looking to cut unnecessary excessive expenditure and protect front-line services to patients, referral to NICE for proper evaluation and impact assessment would meet the national Interest AND benefit patients too.

If you think likewise, it's time to let our new MPs and Health Minister know our deep concerns about HTM01-05 as it stands!

Tony.

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Raj Pancholi
well done Tony,
as always well thought and written article.
thumbs up for the time you put in to elevate and educate our profession

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Ruth Dening
Thank you - well reasoned article. I have spent absolutely hours and so have my staff on trying to get all the paperwork done, all the audits and evidence. I have bought 8 lever-arch files and am steadily filling them. I used to go out and have a little walk at luchtimes, now instead I am reading and re-reading HTM 01-05 so that I don't miss anything for when we register with the CQC and they come round and interview me. The pre-acceptance waste audit wasn't mentioned in the guidelines or I couldn't find it and then we had about 5 days to get that to the waste companies. I feel like its a gigantic game of chess.
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Keith Hayes
Absolutely agree. Now is anyone in DH sensible enough to take it on board, let's hope so!
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Amjad Malik
A great article - thank you
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James Mehta
Well done Tony. Excellent synopsis of the current situation. Thank you for your efforts.
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Prof. Andy Bates
Excellent
Brilliant, well thought out article.


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