Please find following our feedback for the consultation phase review of the equine dentistry continuous improvement project. Our major concerns are:

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1 28 January 2011 Ms Michele Jackson At.All.Events Pty Limited PO Box 231 CREMORNE NSW 2010 Dear Michele, Please find following our feedback for the consultation phase review of the equine dentistry continuous improvement project. Our major concerns are: Maximum depths for rasping teeth need to be specified to avoid opening pulps. Tooth extractions are invasive procedures that should only be undertaken by veterinarians while horses are provided with appropriate sedation, pain relief, anti-inflammatory or antibiotic medications. Powered instruments require sedation of the horse and their use is risky in even the most experienced hands. A veterinarian must administer sedation of the horse and be present to provide emergency care whenever they are used, so the Australian Veterinary Association maintains that only veterinarians should use power tools on horses teeth. Many of the procedures outlined in the diploma package such as endodontics required advanced medical and dental training to undertake effectively and safely. Anyone wanting to undertake these procedures on any animal must undertake a veterinary degree, and for most of these competencies, additional postgraduate dental training is also required. The advice in the following feedback form is based on current knowledge of advanced equine dentistry and is supported by the scientific literature, particularly the references listed in the additional comments section at the end. Above all, our primary concern is for the welfare of horses and we have grave fears that the implementation of the national training package in its current form (particularly the Diploma) will have serious consequences for Australia s horses. In addition to these specific concerns, there are several issues associated with the development of the national training package that we find worrying, but that do not fall within the scope of this consultation. While we support the accreditation of equine dental technicians, we remain concerned about how the development process has been conducted, and that insufficient weight has been given to the knowledge and views of the largest and most highly trained group working on horses teeth veterinarians.

2 We are also concerned about the practicality of implementation of the training package. We are concerned that there may not be enough appropriately skilled trainers available, and that sub-standard teaching and assessment will result. This could have a devastating impact on horse welfare as well as consumer protection through the work of accredited providers with substandard skills. The most important consideration for the veterinary profession is the need for national regulation of the work of equine dental technicians. It is vital that they are accountable for their decisions just as veterinarians are accountable to state and territory veterinary boards. While we understand this is beyond the remit of AgriFood Skills Australia, we are extremely concerned that this crucial step will get lost once the package is finalised. The Australian Veterinary Association can see a viable way forward to national accreditation of equine dental technicians. We see equine dental technicians continuing to work in partnership with veterinarians as many currently do, providing basic dental services of examining, cleaning and rasping teeth. It is common for dental technicians and veterinary nurses to work alongside veterinarians in small animal practice, just as human dental technicians work with dentists. This is the model for successful collaboration and delivering better care for horses.. The way forward as we see it is: Finalise the Certificate IV qualification with some minor amendments to exclude extractions and clarify that the use powered instruments is excluded. Abandon the Diploma qualification anyone wanting to undertake these types of advanced procedures should undertake a veterinary degree and any additional postgraduate dental training that is required. The Australian Veterinary Association is committed to seeing this process through, and to maintaining our active participation. Thank you for the opportunity to comment once again on the draft training package. Yours sincerely, G. Barry Smyth President

3 EQUINE DENTISTRY CONTINUOUS IMPROVEMENT ACM10 ANIMAL CARE AND MANAGEMENT TRAINING PACKAGE FEEDBACK FORM Consultation Phase Review Return all feedback information by: COB Friday 28 January 2011 To: Michele Jackson, At.All.Events Pty Limited Fax: Post: PO Box 231, CREMORNE NSW 2090 All enquiries should be directed to: Michele Jackson - Tel: Mobile: Note: Groups or individuals providing feedback must complete and forward the FEEDBACK FORM to provide their contact details and a context to their feedback. All contact details will remain confidential. Draft materials can be accessed from the AgriFood Skills Australia website: Please record your support and/or comments for the Equine Dental draft qualification packaging and units of competency below: Contact details Name Organisation Dr Bruce Twentyman Australian Veterinary Association Telephone btwentyman@ava.com.au Other stakeholders who have contributed to this feedback are: Name Position Organisation Dr G. Barry Smyth President Australian Veterinary Association Dr Wayne Fitzgerald Committee member Australian Veterinary Dental Society Add more rows if required

4 Review feedback Responses are sought on the following areas: 1. The suitability of units to the work roles in the equine dental industry sector 2. The technical coverage of the units for equine dental and oral care knowledge and skills 3. The work performance described in the Elements and Performance Criteria for each unit 4. The critical aspects of evidence required to achieve each of the competencies Please record your support and/or comments for the Equine Dental draft qualification framework and units of competency below: 1. I/we provide this feedback based on: (please delete whichever does not apply): No a. Review of the Consultation Phase Explanatory Notes information ONLY YE S Yes b. Review of the Consultation Phase Explanatory Notes information AND Review of the full draft material documents circulated with the above paper. c. Other - please provide details: Review of all available documentation provided to the public and the National Reference Group 2. 1/we support the draft Qualification packaging and support preparation for stakeholder validation review. Yes a. Draft Certificate IV in Equine Dentistry Please provide additional comments here regarding the basis of your response: However, the job title Equine dental service provider is a generic term that may be confused with veterinary equine dental service providers. The AVA thinks the term Equine dental technician is more accurate, and reflects similar para-professional roles such as veterinary technician or human dental technician. It is also the term used in the United Kingdom. No b. Draft Diploma of Equine Dentistry Please provide additional comments here regarding the basis of your response: The qualification packaging outlines competencies that are advanced and often invasive treatments that can only be safely undertaken by veterinarians with advanced training. 3. 1/we support the draft Units of Competency and support preparation for stakeholder validation review. No a. Units of Competency packaged in the draft Certificate IV in Equine Dentistry Please provide additional comments here regarding the basis of your response While generally supportive of most of the competencies in the Certificate IV package, the AVA does not agree with the inclusion of extractions of any kind and feels that the exclusion of power tools needs to be clarified further. (Please refer to detailed comments on units.)

5 No b. Units of Competency packaged in the draft Diploma of Equine Dentistry Please provide additional comments here regarding the basis of your response: This draft package includes competencies that are advanced medical treatments and can only be safely undertaken by veterinarians with advanced training. It also includes the use of power instruments such as cutting tools that have been demonstrated as unsafe. The AVA is concerned that the use of power tools is risky in even the most experienced hands, and a veterinarian must administer sedation of the horse and be present to provide emergency care whenever they are used. For these reasons, the AVA maintains that only veterinarians should use power tools on horses teeth. Tooth extractions are invasive procedures that should only be undertaken by veterinarians while horses are appropriately sedated. If required: Please provide your additional comments/feedback EITHER BY using Microsoft track changes on the distributed documents and forwarding these with this form, OR complete the relevant section/s on the following page.

6 Unit comments: UNIT CODE/TITLE SECTION (eg. descriptor, elements, P.Cs, range statement etc) COMMENT ACMEQD402A Range statement Vestibular does not make sense in this context and should be deleted ACMEQD404A Performance criteria The correct term is rostro-caudal. Anterior posterior should be deleted. ACMEQD404A Required knowledge Impact of sedation on horses. While knowledge on this issue is fine, it should be underlined that the prescribing, administration and monitoring of sedation is not included and a veterinarian must do this. ACMEQD404A Range statement - routine dental correction and oral procedures 1) removal of retained deciduous caps should be removed as no extractions should be undertaken by technicians at this level. 2) removal of sharp enamel points and removal of sharp points with dentine only should be restricted to a maximum of 3mm in molars and 1 mm in incisors and canines to avoid approaching the pulp. 3) extractions of any kind should be removed as loose teeth or tooth fragments only occur when there is significant pathology or injury that requires investigation. There are also indications that mean removal may be inappropriate for the animal, and imaging such as x-rays is often required before committing to surgery. 4) removal of sharp points with dentine only on upper and lower buccal and lingual edges removal of sharp points with dentine only on upper and lower buccal and lingual edges needs to be reworded as it s open to misinterpretation. This point and the previous one should be replaced with a single more precise point: removal of sharp points with enamel, dentine and cementum on upper and lower buccal and lingual edges are removed under close scrutiny to a maximum depth of 3mm in molars to avoid proximity or exposure of any pulp canals.

7 ACMEQD404A Range statement - conditions that may be recognised but which require referral include: 1) anterior/posterior displacement is ambiguous terminology and should be replaced perhaps with brachygnathia or prognathia if either or these are what s meant. 2) caries should be specified as peripheral and infundibular-cemental caries 3) Cheek teeth dentine or cementum reduction of more than 3mm should be added as a dot point. 4) We agree that retained deciduous caps should be referred this item belongs in the referral list rather than the routine dental correction list (see reasons above). ACMEQD405A Range statement 1) manual cap extraction, loose permanent tooth removal not requiring tools or elevation of mucosa, and loose permanent tooth removal requiring tools but not elevation of mucosa should all be moved to the list headed referral for: Loose permanent teeth are rare and can only indicate serious trauma. They should only be treated by an experienced veterinarian. ACMEQD406A Performance criteria prepare for routine dental correction. 1) Impacted feed is a sign of periodontitis and referral is not optional for a horse with this condition. This point should read Impacted feed is removed and a referral made for treatment of probable periodontitis. 2) Treatment of loose or retained caps is the same as extraction, and this should be referred to a veterinarian. 3) Canines are cleaned and modified as required should be amended to Canines are cleaned and modified if required by rasping sharp points to a maximum of 1mm to ensure clarity and to avoid pulp exposure. ACMEQD406A Required skills and knowledge 1) Monitor horse vital signs is not necessary as the veterinarian present is fully responsible for the horse and any monitoring required during sedation. This should be removed.

8 ACMEQD406A Range statement 1) manual cap extraction, loose permanent tooth removal not requiring tools or elevation of mucosa, and loose permanent tooth removal requiring tools but not elevation of mucosa should all be moved to the list headed referral for: Loose permanent teeth are rare and can only indicate serious trauma. They should only be treated by an experienced veterinarian. ACMEQD501A Whole unit This unit should be deleted from the package. Due to the risk of severe accidental damage to teeth and the potential need for emergency treatment, as well as the need for sedation, power tools should only be used by appropriately trained veterinarians. Rotating cutting discs should never be used by anyone (Easley 1998). The attending veterinarian is responsible for all sedation and monitoring. Endodontics is an advanced medical treatment that can only be safely undertaken by a veterinarian. ACMEQD502A Performance criteria 1) Rostro-caudal is the correct terminology anterior posterior should be deleted. ACMEQD502A Required skills and knowledge 1) All the skills listed in in conjunction with the attending veterinarian are the veterinarian s responsibility and should be deleted as not required. 2) the importance of hygiene and infection control cannot be overstated. Standards of routine hygiene should be specified e.g. surgical gloves, masks and protective glasses worn for anyone performing these examinations and procedures.

9 ACMEQD502A Range statement 1) The details of the advanced or staged corrective work should reflect the comments made earlier in relation to rasping cheek, incisor and canine teeth, removing impacted feed etc. 2) The rasping of incisors is widely misunderstood and almost never called for (Queensland Civil and Administrative Tribunal 2010). This should be reflected in the detail of this unit 3) Tooth extraction is an invasive, usually surgical, procedure and should only be conducted by a veterinarian. Parameters of intra-oral extraction assessment should be deleted. ACMEQD503A Whole unit See previous comments in relation to: 1) the responsibility of the veterinarian for all matters relating to sedation 2) exclusion of the use of powered instruments from this package 3) maximum safe depths for filing cheek teeth, incisors and canines 4) invasive procedures such as extractions should be deleted as these are either surgical procedures or indicative of probably underlying pathology or trauma that require assessment by a veterinarian 5) endodontics is an advanced medical treatment that can only be safely undertaken by a veterinarian with postgraduate training and skills, and should be deleted from the unit. 6) diamond or rotary cutting wheels should never be used by anyone all reference should be deleted and this exclusion should be noted in the unit competencies. ACMEQD504A Whole unit This unit should be deleted. Extractions are either surgical procedures or indicative of probably underlying pathology or trauma that require assessment by a veterinarian.

10 ACMEQD505A Whole unit See previous statements in relation to sedation, powered instruments, invasive procedures and endodontic treatments. The skills and knowledge in this unit require extensive medical training to understand and master. Any person wanting to safely undertake these treatments on a horse needs to complete a veterinary degree. This unit must be deleted. ACMEQD506A Whole unit See previous statements in relation to sedation, powered instruments, invasive procedures and endodontic treatments. The skills and knowledge in this unit require extensive medical training to understand and master. Any person wanting to safely undertake these treatments on a horse needs to complete a veterinary degree. This unit must be deleted. Qualification Framework comments: QUALIFICATION SECTION (Qualification Notes, Core / Elective unit packaging) COMMENT Employability Skills Summary comments: QUALIFICATION EMPLOYABILITY SKILL COMMENT Use this space to provide other comments regarding units or qualifications.

11 The Australian Veterinary Association supports the accreditation of equine dental technicians as the first step towards licensing or other formal regulation. However we have serious concerns that many of the proposed competencies are not able to be mastered in the context of vocational training, and require the medical education of a veterinary degree as well as appropriate work-related experience to undertake safely. The result of people attempting procedures with inadequate knowledge or training is serious injury to the animal leading to pain, suffering and sometimes death. The advice in this submission is based on current knowledge of advanced equine dentistry and is supported by the scientific literature, particularly the references listed here. Above all, our concern is for the welfare of horses and we have grave fears that the implementation of the national training package in its current form (particularly the Diploma) may have serious negative animal welfare consequences for Australia s horses. References American Association of Equine Practitioners. Equine cheek tooth removal per os. What is and what is not an act of veterinary surgery? Proceedings of the AAEP Focus Meeting 2006 Indianapolis USA. Easley JW. Dental corrective procedures. In: Gaughan EM, DeBowles RM, editors. Veterinary clinics of North America; equine practice; dentistry. WB Saunders Co, London, 1998:429. Queensland Civil and Administrative Tribunal, Veterinary Surgeons Board of Queensland v MacIntosh [2010] QCAT 601. Available at: retrieved 27 January Rucker BA, Carmalt JL. Measurement of equine cheek tooth pulp cavities from mesial and caudal tooth edges. Proceedings of the American Association of Equine Practitioners, 2004 annual meeting. In press. White C and Dixon PM. A study of the thickness of cheek teeth subocclusal secondary dentine in horses of different ages. Equine Vet. J 2010;42: Wilson GJ, Walsh LJ. Temperature changes in dental pulp associated with use of power grinding equipment on equine teeth. Aust Vet J 2005;83: Windley Z, Weller R, Tremaine WH, Perkins JD.Two- and three-dimensional computed tomographic anatomy of the enamel, infundibulae and pulp of 126 equine cheek teeth. Equine Vet J 2009;41: