July 3, 2009
Dr. John Reitz, Chair
State Board of Dentistry
Bureau of Professional and Occupational Affairs
Pennsylvania Department of State
P.O. Box 2649
Harrisburg, PA 17105
Re: PDA’s position on Botulinum toxin A (Botox) Injections
Dear Dr. Reitz:
On behalf of the more than 5,500 members of the Pennsylvania Dental
Association’s (PDA), I thank you for the opportunity to share PDA’s position on
the administration of botox injections for dental patients. It is our understanding
that the State Board of Dentistry’s (SBOD) committee on scope of practice dental
issues, chaired by Dr. John Erhard, may develop a policy statement or
regulations for consideration by the full SBOD.
PDA’s Board of Trustees and Council on Government Relations conducted
lengthy discussions and agreed to the following recommendation for the SBOD
to consider adopting as a policy statement or regulation:
Injection of botulinum toxin A (botox) and other injectable pharmaceuticals in the
oral and maxillofacial areas are within the scope of the practice of dentistry. Just
as in all phases of dentistry, the dentist should only be using these modalities if
he or she has been appropriately trained in all aspects of their use, including
diagnosis, treatment planning, possible complications, as well as the techniques
used.
PDA believes that adopting this recommendation as a policy statement or
regulation provides sufficient guidance to dentists who are making decisions
whether to offer these services to patients. There is no need to micromanage the
practice of dentistry to the degree of detailing what is needed to achieve
competency. Educators should be allowed to determine competency standards
and individual practitioners should be given the discretion to determine whether
they have achieved a comfort level to perform these types of procedures.
PDA uses as an example how the dental profession handles dental implants. No
dental specialty has complete jurisdiction over this procedure and the SBOD
does not provide specific regulation or requirements on licensees to place and
restore dental implants. We believe the same rationale should apply to botox
injections and the injection of other pharmaceuticals.
We look forwarding to continuing to work with you all on issues impacting the
profession and the patients we serve. Thank you for considering PDA’s position
as the SBOD moves forward with its deliberation on establishing policy or
regulation regarding the administration of botox injections.
Please do not hesitate to contact me at any time if you have questions about
PDA’s position on botox injections or if you need further information. Or you may
contact PDA’s government relations staff at 717.234.5941, who are also
available to respond to your requests.
Sincerely,
Andrew J. Kwasny, DMD, MSD
President
(814) 455-2158
kwas2@live.com
cc:
Dr. John Erhard, chair, Scope of Practice Committee
Pennsylvania Society of Oral and Maxillofacial Surgeons
Pennsylvania Academy of General Dentistry
Pennsylvania Academy of Pediatric Dentistry