Well another week, another major document to chew up...
A mere 98 pages for this one -a mere 4 years in the making and of course I could be referring to the Hobbit . But that is no way to refer to the esteemed CDO [of the DH, or NHS England, or the deputy underling CDOs- you choose which job is being shared in the new logo-free Department of Health]. And no, I am not referring to 50 Shades of Porcelain.
Calm yourselves , but its true. HTM 01-05 [2013 edition] has or is about to thud its way into your inbox. And a riveting piece of contraceptive literature it is.
Of course instead of highlighting the differences between the documents, in a formal, living document method, the whole text has to read alongside the 2009 edition to see where the changes are… so you need both copies on the desk. What, you mean you can’t find the other? Shame on you, you bug ridden cesspit of casuality, you!
Let me skip you to the good news. Paragraph 2.4k – leave them in the bags for a year now – shhh… you are not supposed to say that ….
Even stranger though: the continuing mystery of what should have been in 2.4l [for Lima] which never made the final 2009 cut is also kept out of the 2013 version. So invisible redaction is alive and well.. Oh well. In this case you could make it up.
Lots of bigger brains than my little apology have cast their eyes over this and its preceding ‘advice’ only to find it a glorified version of Civil Service speak for ‘our opinion is worth more than yours’. As we remind ourselves of the numerous infection related deaths, epidemics and microbial population flares that have arisen over the years from day to day dentistry, what exactly is the purpose of HTM 01-05 in dentistry?
One assumes that this stuff is taught to the point of theatrical performance at Dental Schools. The implication is that much of the EU now adopts such thinking. If all of that is true why do the Department of Health feel the need to allocate so many resources of manpower to such a tome? The first evidence they should present is the stuff to prove there was even a problem in the first place!
I love it when the preamble states
It is not the intention within this suite of documents to unnecessarily repeat international or European standards, industry standards or UK Government legislation. Where appropriate, these will be referenced.
So we are to assume that while a 5 years degree confers an assumption of learning ability we are not be trusted with reference to the documents that are causal in the need for 98 pages of …[ you fill in the adjective of choice]. Stuff transparency – we know better and you do not need to know. How very quaint, how deliciously old fashioned. How unfit for purpose the arrogance of the DH makes them.
Another quote caught my eye for all you entrepreneurs out there:
Where new practices are commissioned or new premises contemplated, it is advised that the full best practice provisions of this guidance be utilised wherever reasonably practicable.
So presumably your essential pre-opening CQC registration will take due note of this…
Don’t you just love this little ‘get-out-of-jail card?
References - It should be noted that this list may not be totally inclusive at the time of reading. Advice should be sought on the currency of these references and the need to include new or revised documents.
Now I am all in favour of good standards. Indeed in a funny sort of way I can understand the need for consistent proper standards in such a basic area of patient safety, and like any proud profession we should be jumping at the chance to trumpet our safety standards to our patients. Ok, so maybe we can argue about the science behind it all, but there is an irrefutable logic.
If the only way to sterilise is to have a validated process , then the only way to wash and disinfect, given the huge variety of human skill and competency, is to use a….washer drier. Patently it does not fix the problems of the world and self evidently they are pain in the neck in the cottage industry of compact, no-free-space practice. But there is a logic to the need for some such technology if we genuinely believe in profession wide standards. The clever bit would be to combine science and evidence with the technological, low cost outcome. But then again, when was the outcome of a Government Department ever to be regarded as clever?
So what happens if in 2015 another 10% of the profession - 1500 practices give or take - use the best practice espoused in HTM 01-05  to argue that they can longer, as independent businesses who must put the safety of their patients above any business need [cf GDC Guidance] decide that compliance with the HTM protocols requires the practice to operate outside the NHS?
For sure it seems that it will be down to practice owners to fund any compliance – and it seems unlikely that there will be any Scottish methods of grant based funding from the English side of the border. Wales is an interesting area though – and we shall see how they handle the matter. Across the water is also a different climate of political process.
So maybe the true unspoken purpose of HTM 01-05  is to force upon dental business owners s who may be eeking to equip a practice such onerous costs that they may prove unsustainable under the nnGDS, but perfectly manageable for for a future outside the NHS?
Many of us have been saying that for years. Maybe as we come out of recession another cycle of the private practice life will begin.
Exciting times, eh Caruthers? And what was paragraph 2.4 l-Lima?