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1 Prevention and Management of Dental Caries in Children guidance update – Consultation Feedback Consultation is the opportunity for anyone with an interest in the guidance to provide feedback and influence its development. We welcome your views on this draft guidance as part of the formal consultation process. Please complete and return this form by 18 August 2017* to: Freepost Licence RSSH-ETXY-ZKBL Email: [email protected] SDCEP (PMDCC Consultation) Dundee Dental Education Centre Frankland Building * Please note that feedback received after Small’s Wynd this date will not be considered. Dundee, DD1 4HN A collation of all feedback received, with our responses, will be available on request. This may identify the source of comments received from an organisation or in an official capacity but not those received from individuals. About you Providing the information requested below allows us to understand respondents’ interests in the topic and to clarify comments, if required. Individuals' personal details will only be used for this purpose and will not be included in collated feedback or otherwise shared. Please note that we are unable to consider anonymous responses. Name: Nicola Kaya Professional role: Policy Adviser Sector, e.g. GDS, PDS/CDS, hospital: GDS, PDS,HDS Responding: as an individual ; on behalf of an organization X If organisation, please give full name: British Dental Association Email address: [email protected] Address: Forsyth House, Lomond Court, Stirling Business Park, Stirling, FK4 4TU Specific interest/role in topic: Questions are included on the following pages under these headings: 1. Guidance Content 2. Illustrations and Supplementary Information 3. Guidance Presentation 4. Guidance Development 5. Implementation 6. Equality 7. Additional comments

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Prevention and Management of Dental Caries in Children guidance update –

Consultation Feedback

Consultation is the opportunity for anyone with an interest in the guidance to provide feedback and influence

its development. We welcome your views on this draft guidance as part of the formal consultation process.

Please complete and return this form by 18 August 2017* to: Freepost

Licence RSSH-ETXY-ZKBL

Email: [email protected] SDCEP (PMDCC Consultation)

Dundee Dental Education Centre

Frankland Building

* Please note that feedback received after Small’s Wynd

this date will not be considered. Dundee, DD1 4HN

A collation of all feedback received, with our responses, will be available on request. This may identify the

source of comments received from an organisation or in an official capacity but not those received from

individuals.

About you

Providing the information requested below allows us to understand respondents’ interests in the topic and

to clarify comments, if required. Individuals' personal details will only be used for this purpose and will not

be included in collated feedback or otherwise shared.

Please note that we are unable to consider anonymous responses.

Name: Nicola Kaya

Professional role: Policy Adviser

Sector, e.g. GDS, PDS/CDS, hospital: GDS, PDS,HDS

Responding: as an individual ; on behalf of an organization

X

If organisation, please give full name:

British Dental Association

Email address: [email protected]

Address: Forsyth House, Lomond Court, Stirling Business Park, Stirling, FK4 4TU

Specific interest/role in topic:

Questions are included on the following pages under these headings:

1. Guidance Content

2. Illustrations and Supplementary Information

3. Guidance Presentation

4. Guidance Development

5. Implementation

6. Equality

7. Additional comments

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1. Guidance Content

Please indicate the extent to which you agree or disagree with the following statements on the five point scale

and provide comments or explanation, as appropriate. For questions 1a-1o ‘adequately covers’ means that

the recommendations are reasonable and sufficient information is provided.

1a) Section 1 (Introduction) adequately covers the

background to the guidance

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland would note that from a restorative dentist’s point of view, the guidance is useful and will be a valuable source for dental care professionals and students. Overall the document is comprehensive and well laid out. It has updated and improved upon previous guidance and it is particularly good to see information sharing and GIRFEC now included. The diagrams and flowcharts will allow it to be used as a quick reference document, which is helpful.

However, BDA Scotland would highlight that there is a major omission in not making a statement that dental caries is almost wholly preventable, with too much emphasis on treatment and not enough on prevention. There is no mention of fluoridated water, which is the most cost effective way of delivering prevention to Scotland’s children where appropriate to local needs. Because it is Scottish Government policy not to implement water fluoridation, this does not mean it should be ignored by the guidance group. BDA members believe that the document is geared to managing and treating disease, which is not what modern prevention is about. Prevention should be from birth and the aim to prevent having any other treatment. BDA Scotland would highlight that there are many countries in the world which have fluoridated water and question why not in Scotland?

BDA Scotland would comment that there is little mention of the parent / carer’s responsibilities in preventing dental disease in children.

BDA Scotland would highlight that on page 5, Items 3-5 d the comments and not referenced, we do not believe the statements are evidence based. The information is not from UN Article 24 see attached Annex 1.

Pages 5 to 6, Section 1.2 ‘Why follow this guidance’ – BDA Scotland questions is there evidence to support the last sentence in this paragraph? How will SDCEP know?

Page 5, Section 2.1.1, item 5 – BDA Scotland suggests re-wording this for clarity. As it reads now it suggests that members of the dental team is leaving disease untreated when it says “even children who access dental care have untreated disease”. The statement should be clarified by explaining that this is likely to be because of anxiety on the part of the child, resulting in non-compliance with treatment of their disease. The document goes on to advise that not all carious lesions require operative management.

These documents should avoid blaming dental professionals for Scotland’s high caries rate in children, which has a multi-factorial aetiology

Page 5, Item 17 BDA Scotland suggests that this should be revised. It appears misleading to suggest that prevention e.g. topical fluoride application, diet advice and fissure sealant is “relatively recent” when this preventive advice has been taught in dental schools for decades.

Page 5, Item 26 – the dental profession needs guidance on GIRFEC and has been calling on Scottish Government and the Cabinet Secretary for detailed guidance for dental patients to include various scenarios.

Page 5, Item 35 – BDA Scotland would be interested to know what other countries would be interested in the Scottish guidance.

Page 5, Item 39, the document suggests that many of the recommendations in the guidance are based on research evidence and BDA Scotland suggests that references are required.

Page 5, Item 40 – BDA Scotland is concerned that there were no general dental practitioners (GDPs) invited to take part in the drafting of the SDCEP guidance, given the effect the guidance will have on GDPs.

Page 5, Items 40-2 – BDA Scotland is concerned that this places the responsibility for rates of dental caries onto the dental team. Caries is a preventable disease caused by high sugar diet with poor tooth brushing. General medical practitioners (GMPs) will not be held responsible for the rise in obesity rates, diabetes and high blood pressure due to the same life style choices.

Page 6 items 9-17 – BDA Scotland would question whether training and resource implications have been taken in account and future provision for implementation to primary care.

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Page 7, Items 2-6 – BDA Scotland would question again the reasoning behind the lack of GDPs on the panel.

Page 7, Item 38 – to note that the FDI World Dental Federation system is not recognised by the British Orthodontic Society.

Page 7, Items 40-41 BDA Scotland questions why, if there is no consensus on the preferred approach as to how caries is measured, has guidance been developed?

Page 8, Items 11-13 – It is vitally important that GDPs are involved with any future guidance from the beginning of the process.

1b) Section 2 adequately covers the overarching

principles

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland would note it is unclear whether this is guidance or a text book. The document contains too much details for a guidance paper and insufficient information for a text book or manual of clinical management.

Page 9 Items 2-29 – BDA Scotland believes that these aims are laudable, but will need to be adequately resourced.

Page 9, Item 11-13 BDA Scotland suggests that the bullet points should be re-ordered to placing, for example, ‘encouraging parent/carer to take responsibility for child’s oral health’ before ‘relieve pain/infection’ because if the disease is prevented there should be not pain/infection.

1c) Section 3 adequately covers assessing the

child and their family

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland notes that this is an extensive section describing all possible assessments required in deciding which pathways for the child. BDA Scotland would highlight the guidance would be difficult to carry out cost effectively under the current Statement of Dental Remuneration fees in practice, however, in reality a massive injection of funding to allow GDP’s to provide this standard of care in the GDS would be required. In addition, there would also need to be more resources for secondary care referral service. Page 11, Items 17-19 - BDA Scotland would note that not all patients know the name of their doctor, and that it is unlikely they would know the name of their school nurse, social worker etc. Some members questioned whether the name of a child’s social worker, school nurse, DHSW should always be recorded in the notes. Page 11, Item 23 – BDA Scotland suggests a line should be added to indicate that if a problem with the developing occlusion is suspected, the patient should be referred to a competent orthodontic practitioner as soon as possible for an orthodontic assessment, with reference to GDC ‘Standard 7.2’

Page 11, Items 24-41 – BDA Scotland suggests this section is dealt with during undergraduate studies.

Page 12, Items 16-29 – BDA Scotland suggests a detailed scenario of common examples should be made available by Scottish Government to help the profession deal with GIRFEC. This will improve the care of vulnerable patients and ensure a national standard with respect to cases of dental neglect. It will inform other agencies of their responsibilities with respect to dental neglect. Without specific dental GIRFEC guidance from Scottish Government, the dentist will be engaging with multi-agency services ‘on their own’.

Page 12, Items 30-45 – BDA Scotland would highlight that there are training and resource issues linked to these items.

Page 13, Items 1-38 – again BDA Scotland suggests there are training and resource issues linked to these items which would have to be addressed.

Page 14, Items 9-13 - ‘Visual diagnosis of dental caries - The “diagnosis of caries” section reads as an operator manual for undergraduate teaching rather than a user-friendly guideline for a busy practitioner.

Page 14, Items 13-31 – Again BDA Scotland suggests this section is dealt with during undergraduate studies.

Pages15, Item 24 - Again BDA Scotland suggests this section is dealt with during undergraduate studies.

Page 18, Item 2 – BDA GDP members would note from personal experience that for example, it could be difficult taking bite wing x-rays on a four year old child.

Page 22, Section 3.4.4 – ‘Assessing dental abscess/infection in primary teeth’ Item 1,’ BDA Scotland notes that there is mention of pulp therapy as a treatment option for abscess/infection and references section 10.8, however this section covers pulp therapy for vital teeth only, there is no information regarding non vital pulp treatment. This was in the previous addition, if this has been removed for a reason, BDA Scotland suggests this would be best discussed in the new guidance.

Pages 24, Items 24-25 – BDA Scotland suggests that there is a requirement for a personalised care plan (see Section 5).

1 2 3 4 5

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1d) Section 4 adequately covers helping the

family manage dental care

Strongly

disagree x

Strongly

agree

Comments:

BDA Scotland suggests that managing dental anxiety in children requires specialist knowledge and skills;, it takes time to do properly. This section has significant training and resource implications. In addition it is not always suited to be carried out in a busy general dental practice setting. BDA Scotland believes that the management techniques are well described, however, there is an issue of unremunerated appointment time in order to comply with the recommendations on gaining rapport. BDA Scotland also suggests that the guidance seems to present training issues for GDPs not seeing only children all the time, compared to those working in a hospital paediatric dental unit or some areas of the PDS who will have had additional training e.g. the section on dental anxiety management and behaviour management. Whilst it is easy to read and informative it does not mean the reader will immediately have the skills or time to apply these methods in general practice. This will form part of the daily routine for paediatric specialists however, this seems to be asking a lot of a GDP.

1e) Section 5 adequately covers defining needs

and developing a personal care plan

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

Please see our response at Section 1c for further information on a child’s personal care plan.

BDA Scotland agrees that the section describes the plans well. We would suggest that care plans could be incorporated into practice management software.

BDA Scotland suggests resources and time will be required. We also suggest that there is requirement for examples of personal care plans. Page 32, Item 27 – BDA Scotland suggests that not all patients will know (or in the case of a social worker, volunteer) the information regarding the name of other health professionals. Evasive parents with something to hide will be very good and supplying a partial history for the abused child. General dental practices do not have a uniform software platform like Trakcare to help engage other health professions in a patient’s management. Even Trakcare has a significant flaw, in that patients who cancel on the day cannot be traced.

1f) Section 6 adequately covers managing pain Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland believes the flow diagram is good, however we would comment that this section of the document reads like an undergraduate training manual.

1g) Section 7 adequately covers caries

prevention

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland suggests it may be necessary to clarify the strength of toothpaste for each age group, since the narrative implies that 1500ppm can be used for under three year olds.

BDA Scotland also suggests that standardising recommended fluoride dosages from Childsmile compared to other available guidance is welcome.

BDA Scotland would highlight that there is no mention of recent evidence that questions efficacy of fluoride varnish studies in Northern Ireland and North of England.

Page 37, Items 16-19 BDA Scotland suggests there are resource and time implications linked to these items.

Page 37, Items 19-26, BDA Scotland fully endorses this section.

Page 40, Section 7.2 - ‘Tooth brushing with Fluoride Toothpaste’ Items 28-30 - BDA Scotland notes that the information on supervised brushing is vague. BDA Scotland believes that it would be advisable to give more guidance than 'until confident in their brushing habits' as stated in the document, this would help with directing parents.

Page 43, Section 7.3, ‘Dietary Advice’, Items 8-9, BDA Scotland suggests if the guidance can only refer to low quality evidence why include it?

Pages 47-51, BDA Scotland members suggest that some of the information is too basic, for example the clinical photographs of applying a fissure sealant and fluoride varnish.

1h) Section 8 adequately covers management of

caries in primary teeth

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland suggests that there is little advice within this section of the guidance when carious lesions are managed by observation or prevention only. The document should highlight that good notes are essential, although this is mentioned in a later section.

BDA Scotland suggests there are resource and time implications linked to these items which is unworkable in GDS under current resources.

1i) Section 9 adequately covers management of

caries in permanent teeth

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

See 1h regarding taking notes. Page 63, Items 33-35, BDA Scotland would suggest in this instance an opinion is sought from an orthodontist in the first instance. Page 63, BDA Scotland suggests that the use of the acronyms ‘FPM’ and SPM’ as first and second permanent molars should be avoided. Page 64, Items 18-20, BDA Scotland members suggest that the ‘Hall technique’ should be used if the operator’s manual dexterity is poor. The Guideline Development Group may wish to reconsider rewording this sentence. Pages 67-68, BDA Scotland would again note the Guideline Development Group appears to advocate stepwise excavation (based on David Rickett’s systematic review 2013), but appears to struggle with how much caries should be removed. BDA Scotland would question whether the evidence for stepwise excavation is sufficiently strong? Page 67, Items 33-34, BDA Scotland refers to Aim: ‘To remove enough caries to provide a long-lasting restoration’ and would note that it is unhelpful. Page 71, Items 29-30, BDA Scotland suggests that the patient must get an orthodontic assessment from an orthodontist specialist, this may mean local networks have to be established to ensure that patients receive timely interceptive evidence based advice. Page 72, Item 89, BDA Scotland questions whether ‘paediatric’ means ‘specialist’ in ‘child dental health’? The patient should be referred directly to the orthodontist, the specialist paediatric dentist will ask for an orthodontic opinion anyway. Page 73, Items 26-32, BDA Scotland suggests patients should be referred for an orthodontic opinion, these decisions should be based on individual patients, developing malocclusion, timing of future orthodontic treatment etc.

1j) Section 10 adequately covers dental

techniques

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland is concerned that this section reads like an undergraduate text book.

Page 78, Section 10.2 ‘Non-Restorative Cavity Control discusses record keeping and in BDA Scotland members’ opinion is good. There is a very extensive description of techniques required to treat children.

Page 91, Items 1-35, BDA Scotland suggests patients should be referred for an orthodontic opinion.

Page 92 – regarding the photographic series, from a restorative point of view, it is unfortunate that there is no wooden wedge placed proximally before and during cavity preparation. The wedge helps separate the teeth, protects the rubber dam and the gingivae and may help protect the adjacent tooth. Page 92, line 19 BDA Scotland questions why an isthmus prepared and shown on the photograph, since the tooth looks sound occlusally. The guideline emphasises the preservation of tooth structure, but this picture is not consistent with that approach.

Page 94, BDA Scotland suggests there are resource implications linked to these items.

Page 95, BDA Scotland would highlight that patients with anxiety should be treated in an appropriate community based clinic. Specialist techniques and training are required for best evidence based care.

1k) Section 11 adequately covers referral for care Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

Figure 11.1 is a good diagram, it is useful.

Page 96, BDA Scotland would ask how many hygienist and dental therapists are currently working independently in Scotland.

Page 96, Section lines 10-12 - BDA Scotland notes that the first statement refers to the PDS providing a safety net for care to a significant number of children who are not registered with a GDP. There has been a move away from this in the last few years. In NHS Forth Valley children are not registered for they are encouraged to attend an independent GDP. BDA Scotland understands that this situation is similar in most NHS Boards. It may not be necessary to remove the statement, but we suggest the wording is changed or altered so that it is not the first statement regarding the PDS.

BDA Scotland also suggests that point is moved down the order of bullet points.

Page 97,BDA Scotland suggests that neither the referring practitioner or the patient will know their CHI number, and social history may be unobtainable. Given that most NHS Boards now used SCI Gateway, this referral letter and the detail in it will not be possible as the number of characters is limited on the referral. Some NHS Health Boards will use this template as a way of rejecting referrals to keep waiting lists down while patients await treatment/examination.

1l) Section 12 adequately covers recall Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland suggests that this section appears to be ‘wordy’ and asks that the key points be summarised in a flow chart format as in Section 11.

1m) Section 13 adequately covers providing

additional support

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland agrees that the GIRFEC detail is useful, although there would still be some obstacles to sharing information around the need for consent to share the information and what exactly to do if consent is not given. The term “alternative legal basis” needs more explanation in this document. Training for GIRFEC should be provided and funded.

BDA Scotland notes that the helpfulness of this guidance is lessened by the reader being repeatedly referred to other documents e.g. “child protection and the dental team”; Information Commissioner’s Office; which if read in conjunction with this SDCEP guidance no doubt provide all the information needed, however we suggest that the key action points from all these documents be summarised in one place again for effective and easy application of the guidance.

Table 13.3 an example of scenarios would be helpful.

1n) Section 14 adequately covers audit and

research

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland suggests that throughout the guidance many of the key recommendations are based on low/medium quality evidence. Targeted research is needed.

1o) Section 15 adequately covers evidence into

practice

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

The use of flow-charts is preferable to present key messages concisely along with a summary document.

Page 109, Not all BDA Scotland members are convinced that one-to-one dietary advice works in dental setting.

BDA Scotland is disappointed that there is no mention of water fluoridation. Local schemes would reach the population that do not attend the dentist. There is also no mention of dental intervention when a child has had a general anesthetic (GA) for the extraction of carious teeth. These children should be assigned ‘high risk for caries’ and appropriate support given. There needs to be proactive intervention to prevent the child returning for a repeat GA in two-three years’ time.

1p) Do you think any additional content should

be included within the guidance?

Yes No Unsure

x

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Comments:

BDA Scotland suggests the guidance document is extensive to the extent it could be used as an undergraduate teaching aid, although some information is too basic for example, page 47 and 51 show clinical photographs of applying a fissure sealant and fluoride varnish. BDA Scotland notes that there is no mention of ‘upstream’ measures to prevent dental disease. The document is focused on treatment and management rather than prevention and on responsibilities of the operator and very little on responsibilities of parents and government. A summary of the key information could be combined from all the documents mentioned in SDCEP.

1q) Do you think any of the current content

within the guidance is unnecessary?

Yes No Unsure

x

Comments:

BDA Scotland believes the guidance overall is comprehensive, but suggests some of the basic information on caries diagnosis and management etc. could be sacrificed (qualified dentists know and practise 99% of this) to allow emphasis on key take home messages for the whole dental team. BDA Scotland also suggests that since this is a re-draft of a 2010 guidance document and as the caries experience of Scottish children has not dramatically improved, SDCEP should look at how effective their effectiveness programme is. This must be a costly piece of work to produce.

2. Illustrations and Supplementary Information

Please indicate how useful or important you think each of the following is on the five point scale. Where

possible, please provide explanations to support your answers (e.g. comment on the level of detail, whether

the information is adequate, if not useful, why not).

2a) Figure 2.1 Overview of the prevention and

management of dental caries in children (page 10)

Not at

all useful

1 2 3 4 5 Extremely

useful

Comments:

BDA Scotland received mixed comments from members with hospital dentists suggesting the overview helps with navigation through this very lengthy document, but offers little else, whilst GDPs suggested that the guidance was very useful there is very little emphasis on prevention.

2b) Figure 6.1 Diagnosis and management of

caries-related pain (page 36)

Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments:

2c) Figure 8.1: Decision making for managing the

carious primary tooth (page 54)

Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments: BDA Scotland refers to illustration on page 54 and their GDP members suggest that the flow chart is too busy and not easy to navigate. The CDG presumably have considered the systematic review: Hoefler V, Nagaoka H, Miller CS, J Dent. 2016; 54:25-32. Long-term survival and vitality outcomes of permanent teeth following deep caries treatment with step-wise and partial-caries-removal: A Systematic Review.

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2d) Figure 9.1: Decision making for managing the

carious permanent tooth (page 65)

Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments:

BDA GDP members were not in favour of this flow chart, because it is text heavy.

2e) Figure 11.1: Assessing management options for

the child with carious primary teeth (page 99)

Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments:

2f) Summary of the Guidance (page 114) Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments:

BDA Scotland suggests that this section should be moved to nearer to the beginning of the document.

2g) Appendix 2 Childsmile/NDIP dental health

surveillance pathway (page 118)

Not at

all useful

1 2 3 4 5 Extremely

useful x

Comments:

BDA Scotland suggests that more clarification for some for these boxes is needed.

Additional Information

2h) How important to the understanding of the

guidance is the inclusion of clinical illustrations?

Not at all

important

1 2 3 4 5 Extremely

important x

Comments:

BDA members suggest that the illustrations are good and help to break up the text.

2i) Is there any other supplementary information

or any supporting tools that you think should be

provided with the guidance?

Yes No Unsure

x

Please provide more details:

BDA Scotland suggests that the decision making illustrations for deciduous and permanent teeth and the management of pain could be provided as a quick reference guide. BDA Scotland would highlight the document does not mention the benefits of water fluoridation. There is no mention of ‘upstream’ measures to prevent dental disease. The document is focused on treatment and management rather than prevention and the responsibilities of the operator with very little on the responsibilities of parents and government.

3. Guidance Presentation

Please indicate the extent to which you agree with the following statements and provide comments or

explanation, as appropriate.

3a) The information is clearly presented (i.e. the

language and format used is helpful)

Strongly

disagree

1 2 3 4 5 Strongly

agree x

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Comments:

BDA Scotland would highlight that the document is focused on treatment and not prevention based.

3b) The key recommendations are clearly stated

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

BDA Scotland suggests that the recommendations are clearly stated, but the strength of evidence is poor.

3c) It is helpful to indicate the strength and basis

for each key recommendation

Strongly

disagree

1 2 3 4 5 Strongly

agree x

Comments:

4. Guidance Development

Please indicate your response to this question and provide comments or explanation, as appropriate.

How confident are you in the manner in which the

guidance has been developed (see Appendix 1)?

Not at all

confident

1 2 3 4 5 Extremely

confident x

Comments:

BDA Scotland is disappointed that there has been no GDP presence on the guidance group and therefore no input towards the guidance which is a major oversight. BDA GDP members commented that the document is unworkable due to lack of resources (both in funding and workforce) and lack of inclusion from the guidance group.

5. Implementation

Please answer these questions assuming the consultation draft of the guidance is published.

5a) What might be the barriers to implementing this guidance?

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BDA Scotland suggests there will be financial and time constraints in general dental practice and that additional resources and time will be needed for some sections of this guidance and is not workable under the current SDR system. BDA members commented that they would aspire to providing this gold standard of treatment /care, however, many GDPs will feel demoralised when they realise it is impossible to deliver under the GDS. GDPs do not have enough time available to deliver this standard of care in practice. Once again BDA Scotland would state that the document is too much treatment focused and there is not enough support for prevention. Responsibility is on operator to deliver guidance and little mention of government/parental responsibility. BDA Scotland is a little concerned that the document is overly ‘wordy’ and reads like a student handout.

5b) What might help the implementation of this guidance?

BDA Scotland suggests that resolution of time and financial constraints, and that a public health campaign to increase parental involvement governmental as well as health care professionals in preventing dental caries and for children’s oral health care is required. There is also a requirement to consider water fluoridation where appropriate, to reduce the need for treatment. We also suggest that examples of personal care plans would be helpful, as well as more flow charts, focus on key ‘take home’ messages, and reducing the amount to read.

5c) If you are in practice, will you have to change

your current practice to fully implement this

guidance?

Yes No Unsure Not

Applicable

x

Comments:

BDA Scotland believes the guidance is comprehensive and that total implementation could only be provided in a specialist paediatric practice with no financial restrictions. GDPs may use the guidance to help with specific cases, although some GDPs members suggested the guidance is unworkable for

the reasons outlined in earlier sections.

6. Equality

This question refers to potential discrimination, including by age, disability, gender reassignment, marriage &

civil partnership, pregnancy & maternity, race, religion or belief, sex, sexual orientation, geographical location

or whether a person is a carer.

Do you think that any particular groups or

individuals (guidance users or patients) are likely

to be discriminated against or disadvantaged by

the guidance?

Yes No Unsure

x

Please provide more details:

BDA Scotland would suggest that unless more resources are forthcoming, dentists will be even more demoralised having to work under this guidance. BDA Scotland believes that communities in deprived areas should have the right to choose fluoridated water.

7. Additional Comments

Please comment on any other aspects of the guidance here. Comments on the relevance and applicability of

the guidance to those who do not work in Scotland are particularly welcome.

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Page 114, Items 5-18, BDA Scotland suggests that none of this advice is new, it equates to the four dental health messages used in the 1970-80s. A campaign highlighting that dental caries is almost entirely preventable and is a direct result of lifestyle choices would empower patients to make better choices for their general and dental health. This needs to be publicised in a national campaign. BDA Scotland would highlight their concern again about the lack of any representation from General Dental Practice to help this SDCEP panel compile this guidance, and yet GDP teams are going to be expected to adhere to this guidance closely. It is interesting that a teacher of dental care professionals was invited to take part, but no GDP. BD Scotland is concerned that SCDEP has lost credibility by not taking into account the financial considerations of running a general dental practice in Scotland today. We note that all members of the SDCEP panel are in salaried positions. BDA Scotland questions whether the practicalities of what is contained in this document been considered. BDA Scotland is concerned that there will be no additional resources for GDPs to allow them to spend the increased time that history, examination and treatment of caries in children outlined in this guidance will take. The document is treatment /management focused and does not take into account the realities of providing care in general practice. BDA Scotland is also concerned that this guidance from SDCEP re-enforces the current Scottish Government policy to reduce the Public Dental Service in Scotland, by shifting the responsibility of treating children with behavioural problems onto general practitioners, and will limit access of children to the appropriate clinicians with enhanced training and time to provide treatment. Members were concerned that practices with a high percentage of children from disadvantaged backgrounds will become uneconomic resulting in the unintended consequence of closure of dental practices in deprived areas and reducing access, thereby increasing health inequalities. BDA Scotland would suggest that the guidance is proscriptive in parts, that if not followed closely, it may be used by parents to claim that their child is not treated appropriately and refer the practitioner to the GDC for fitness to practice. The level of evidence for a patient to refer a dentist/health care professional to the GDC is worryingly low. BDA Scotland urges Scottish Government confirm in writing that any guidelines produced by SDCEP will be fully funded and deliverable by the GDS. In the past SDCEP and Scottish Government have not fully communicated information about guidance and deliverability, for example, the SDCEP Prevention and Treatment of Periodontal Diseases in Primary Care Dental Clinical Guidance which are not deliverable under the NHS. Page 37, line 16-19 BDA Scotland suggests that there is are implications with regard to resource and timing. Page 88, line 17 - BDA Scotland would highlight that there is a typo ‘burr’ should be ‘bur’.

Annex 1

UN Article 24

1. States Parties recognize the right of the child to the enjoyment of the highest attainable standard of health and to facilities for the treatment of illness and rehabilitation of health. States Parties shall strive to ensure that no child is deprived of his or her right of access to such health care services.

2. States Parties shall pursue full implementation of this right and, in particular, shall take appropriate measures:

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(a) To diminish infant and child mortality;

(b) To ensure the provision of necessary medical assistance and health care to all children with emphasis on the development of primary health care;

(c) To combat disease and malnutrition, including within the framework of primary health care, through, inter alia, the application of readily available technology and through the provision of adequate nutritious foods and clean drinking-water, taking into consideration the dangers and risks of environmental pollution;

(d) To ensure appropriate pre-natal and post-natal health care for mothers;

(e) To ensure that all segments of society, in particular parents and children, are informed, have access to education and are supported in the use of basic knowledge of child health and nutrition, the advantages of breastfeeding, hygiene and environmental sanitation and the prevention of accidents;

(f) To develop preventive health care, guidance for parents and family planning education and services.

3. States Parties shall take all effective and appropriate measures with a view to abolishing traditional practices prejudicial to the health of children.

4. States Parties undertake to promote and encourage international co-operation with a view to achieving progressively the full realization of the right recognized in the present article. In this regard, particular account shall be taken of the needs of developing countries.

Thank you for taking the time to contribute to this consultation.

Our consultation process aims to be transparent and, on request, we will provide a summary of comments

received and our responses. This summary may identify the source of comments received from an

organisation or in an official capacity but not those received from individuals.