The Faculty of General Dental Practice UK (FGDP(UK)) has responded to a consultation on draft advice for dentists on the phase-down of the use of dental amalgam.
The Scottish Dental Clinical Effectiveness Programme (SDCEP) is developing the guidance, which dentists throughout the UK would be expected to adhere to, following the implementation of EU Regulation (EU) 2017/852 on Mercury.
The guidance will aim to provide information on alternative approaches to amalgam use, and to help dental teams interpret, and patients understand, Article 10(2) of the regulation, which requires that from 1 July 2018, dental amalgam "shall not be used for dental treatment of deciduous teeth, of children under 15 years and of pregnant or breastfeeding women, except when deemed strictly necessary by the dental practitioner based on the specific medical needs of the patient".
While fully supportive of these aims, FGDP(UK) has expressed a number of concerns.
The draft guidance recommends dentists to apply fissure sealants as preventive measures to all children, in contrast to the recommendation in Public Health England’s Delivering Better Oral Health, which is to fissure-seal permanent molars in children aged seven and up, and only then for children whose teeth ‘give concern’ to the dentist. The Faculty is concerned that such a recommendation, in a document intended for UK-wide use, risks confusion in the profession, with potential dento-legal implications.
FGDP is also concerned that the draft advice for treating breastfeeding or pregnant patients is limited to postponing non-urgent treatment for those who are pregnant. This appears to be the result of a precautionary recommendation by the European Commission’s Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) that as with dental amalgam, the placement or removal of alternative materials in pregnant women should be avoided if possible – despite it finding no evidence of harm in either case. The Faculty has asked that SDCEP ensure that the final document is definitive as to the recommended alternative materials and approaches for treating breastfeeding and pregnant patients, as it already is in relation to primary teeth and for patients under 15 years old.
The Faculty also anticipates patient misunderstanding of the new rules, as there is an incongruence between the stated environmental motive of the regulations, and the apparent safety issue suggested by their discrimination between patient groups during the phase-down. FGDP believes that some patients, for whom an amalgam filling remains the most appropriate option, will become understandably concerned that the material their dentist is recommending is apparently unsafe for children and foetuses, and conversely that those advised to receive a filling of an alternative material may think that the dental practice is persuading them to choose a more expensive option in its own interests. FGDP welcomes the fact that SDCEP has drafted information leaflets to aid practices in communicating the changes to patients, but feels these could be improved.
The regulations also set out a wide a range of other measures for later implementation, with the next key date for dentists being 1 January 2019, after which dental amalgam can only be used in pre-dosed encapsulated form, and the use of amalgam separators will become mandatory.
The full consultation response is available at https://www.fgdp.org.uk/policy-reports-and-consultations.