Regarding the Dentists’ lobby, the Vice President warned:
“Lobbyists have recommended setting the minimum qualifications to practise Dentistry, in the EU, as that of a Dentist. This ignores the independent practice of Denturists / CDTs, already recognised in EU Member States (MS). It will restrict the PARTIAL ACCESS covered within the scope of practice for Denturists in the provision of Custom-Made Dental Devices (CMDD), directly to the Public. Denturists / CDTs have practised safely in Europe and internationally for many years, without any threat to Public Health.
Our European Committee recommends that, Partial Access to be included in any revision of Directive 2005/36/EC for the provision of dentures, by qualified Denturists / CDTs and that the profession is recognised separately from Dentists.”
Denturists provide less costly oral care for patients who cannot afford to pay for services offered by dentists. The poor are entitled to a high level of health protection in all European Union countries as much as the wealthy. The EU strives for health to be included in all policy areas, and when it comes to disease prevention and health promotion there should be an ‘all hands on deck’ attitude, and not a turf war. Early access to disease prevention is to be encouraged not shackled. In reality, denturists can also serve as an early warning signal.
Another warning signal given by the Vice President in the said letter concerns Article 4 and the free movement of devices:
“Providing the CMD (dentures) satisfies the requirements of the MDD 93/42/EC, Members States cannot obstruct the supply to European consumers. This is quoted in Article 4 (2) of the Directive, as the device and conformity statement fulfils all legal requirements.
Although Denturists are not regulated in all MS, it is clear the Directive on Professional Qualifications and the MDD allow these professionals to provide goods and services in all Member States.
Allowing Dentists and Dental laboratories to retain this monopoly is not in the interest of EU citizens and Single Market policies.”
The second question
2). If the answer is in the affirmative, is the proposed request that clinical dental technologists who originate from other Member States should be entitled to exercise their profession in Malta without it being necessary that patients are referred to them by a person who exercises the dentistry profession, compatible with Directive 2005/36, and in particular with Article 36 thereof in so far as the qualification of clinical dental technologist is not included among the qualifications for training mentioned in point 5.3.2 of Annex V of this Directive ?
The rules concerning the coordination of the profession of dentists are to be found in Articles 34 et sequitur of the TFEU (Chapter 3) and in Annex V (point V.3) of Directive 2005/36/EC. Annex V only refers to Dentists who have harmonisation (that is, standardisation) in their training and education. Clinical dental technology is listed in the General system.
Denturists or clinical dental technicians / technologists / special technicians [according to the nomenclature applicable in the particular Member State] are listed within the General system, where professions do not possess harmonisation in their education and training from one Member State to another. The International Federation of Denturists, however, has stipulated the Baseline Competencies which the EU Member States having regulation of clinical dental technologists acknowledge but do not implement. The International Federation of Denturists registered with the EU Transparency Register is presently formulating an international accreditation status for educational institutions. In the Selective or Sectoral system this refers to all professions with harmonisation of education in which the dental practitioner (dentist) is included.