AN OPEN LETTER TO THE PRESIDENT AND EC MEMBERS OF THE EXECUTIVE COUNCIL OF THE DCI
Respected sirs and madams,
I happened to see a memo from the office of the DCI restricting the conduct of any kind of course not pre approved by the Dental Council of India ( No De-110(186)(complaint)-2018/457. This obviously sponsored notice, coming as it does at this point of time, seems to suggest that all programmes aimed at providing knowledge or refreshing skills must have the approval of the Dental Council of India.
Respected president and members, I beg to differ, like thousands of others, because the DCI has no such powers to curtail the improvement or renewal of knowledge and skills from qualified persons with or without the sanction of the DCI. The notice cites sections 10, 10A, 10B, 51 and 52 to make the fallacious argument that the DCI is the custodian of all clinical learning or updating. It has freely and wrongly interpreted the meaning of the term ' qualification' to mean competence or acquisition of knowledge and skills. I hope the statutory body had spent a little more time taking a legal and grammatical opinion before coming out with such an ambiguously framed memo hindering the fundamental right to learn and benefit society.
Sirs and madams, the heading of section 10 of the Dentist Act refers to registrable qualification. I am sure that you are aware that the medical and dental statutory bodies regulate only registrable degrees which indeed are qualifications. The prime registrable degree in dentistry is BDS . A registered dentist with a BDS is allowed to practice dentistry including all specialties depending on their interest, ability and training. The postgraduate qualification is only an additional or add on registration. Add on Registration for post graduation essentially permits one to become a teacher in a college approved or recognised by the DCI. It does not provide exclusivity of clinical practice in a specialty, as India ' DOES NOT HAVE' a separate specialty register.
In other words, the members of the statutory body must understand, that a qualified BDS graduate can do Endodontics, Oral surgery, periodontics or orthodontics according to his expertise which is achieved through experience, practice and skill enhancing programmes. Where they obtain these additional skills within the purview of dentistry is not the business of the DCI . This is made clear in the definition of 'recognised dental qualification' in chapter1 (j) which includes only 'qualification in the schedule'. In which part of the schedule are there references to refresher courses recognised by DCI, sir???
Section 10(2) requires all these qualifications to be entered in the schedule. Which courses other than those offered by recognised dental colleges are included sirs? Are the courses conducted by IDA or Specialty associations part of the schedule? Does the DCI have powers and guidelines to include them? NO! Quoting section 51 and 52 in the aforesaid memorandum/ notice is at best a wrong interpretation and at worst an attempt to mislead. These sections only refer to practice of registered dentists and has nothing to do with acquisition of further skills and knowledge by them.
In fact the code of ethics regulation ( of which I was one of the draftees) encourages the acquisition of knowledge without conditions. It exhorts dentists to continuously upgrade skills in Chapter I, 3.2 and subsections. Nowhere does it say that imparting knowledge and giving a certificate of experience is unethical as implied in your notice.
Let me try to cite an example. Several hospitals provide Basic and Advanced life support training for a fee. The same with Trauma Life Support. Does the DCI have to whet every certificate programme in every hospital or institution in India and abroad to have a current training record in BLS, which you will agree is an essential part of safe practice. Skill renewal and enhancement can be provided in formal and informal settings with and without certification from a person with established skills. Dental practitioners get trained by other practitioners in the use of new techniques and materials. They attend courses conducted by industry pioneers and manufacturers of new devices and equipment. What has DCI to do with these?
Medical science has advanced only because of these courses which cannot be or has not been provided in teaching institutions during their limited course of study. In fact the need has arisen because many recognised dental colleges have not been able to provide the knowledge and skills as prescribed in the curriculum.
Sirs and madams, I request you to withdraw the memorandum which was issued in haste. If indeed the Dental Council wishes to bring in regulation for accreditation of providers of knowledge and skills, please create terms of reference, guidelines and make amendments to the constitution rather than issue fiats which retard the continuous enhancement of knowledge and skills by imposing unreasonable and unconstitutional bars on the dissemination of information.
Reg No 10285 ( TNSDC)
Past President AOMSI