Policy type: Position statement
Date ratified: May 2019
Note from the NZVA Chief Veterinary Officer (not board approved)
The Ministry for Primary Industries (MPI) are undertaking public consultation on the proposed regulations relating to the 2015 amendment to section 16 of the Welfare Act (effective May 2020).
The proposed regulations:
- ensure that equine dental technicians can continue to perform routine dental floats (the majority of equine dental work) – the NZVA is not objecting to this proposal.
- make equine dental extractions a veterinary-only procedure (ie. they meet the criteria in section 16).
- preclude cutting of teeth unless preceding an extraction by a veterinarian.
Both proposed regulations relating to equine dentistry allow non-veterinary equine dental technicians to remove deciduous incisors/cheek teeth. Proposal 1 allows for tool use on loose teeth; proposal 2 allows for finger-loose "cap" removal with no tools by non-veterinary persons.
The NZVA supports option 2.
The NZVA’s position, which is not law, and is not being consulted on is below. This helps to determine the standard of behaviour and practice expected of the profession.
The NZVA believes that all dental procedures on horses and all equidae should be performed by veterinarians and be based on sound scientific knowledge, evidence-based medicine and surgery, and best practice standards.
In the broad sense, "veterinary medicine" refers to the science of veterinary medicine and surgery, and includes:
- the diagnosis and treatment of animals for the prevention, alleviation or correction of disease, injury, pain, defect, disorder, or other similar condition
- the provision of a service prescribed by regulation in the Veterinarians Act NZ 2005, and
- the provision of advice in respect of a matter referred to in section 16(a) and (b) of the Animal Welfare Act 1999 (from May 2020; see below).
Equine oral health care includes, where necessary, the provision of appropriate and skilled equine dentistry procedures.
While the NZVA position is that all dental procedures should be undertaken by a veterinarian, the Association acknowledges that New Zealand’s current regulatory environment does not preclude equine dental technicians (EDTs) undertaking equine dental work. Accordingly, guidelines have been produced that detail which procedures the NZVA considers appropriate for EDTs, and EDTs working under veterinary supervision, to undertake. These can be found in the NZVA Position Statement 10i – Supervision of Equine Dental Technicians.
It is the responsibility of veterinarians to determine whether an equine dental procedure may be referred, to whom it may be referred, and what level of supervision is required.
The Veterinary Council of New Zealand (VCNZ) Competency Standards state, “veterinarians must recognise their limitations of knowledge and experience and refer for advice and/or treatment in situations where the animal requires a greater level of knowledge and/or skills.” Therefore, if unwilling or unable to perform equine dental procedures, veterinarians have a professional obligation to “make(s) appropriate referrals” (Section 2, Veterinary Practice, VCNZ Code of Professional Conduct).
Where equine dental procedures are performed by EDTs in the absence of veterinary supervision, the NZVA believes these procedures should be restricted to uncomplicated tooth floating/rasping (NZVA Equine Dental Procedures Category 1).
Where appropriate and presuming the veterinarian is satisfied regarding the competency of an EDT, that EDT may perform other dental procedures, whilst under the direct and continuous supervision of that veterinarian (NZVA Equine Dental Procedures Category 2).
In New Zealand, there is no regulation of people providing equine dentistry services, except when that person is a veterinarian, who is bound by the Veterinary Council of New Zealand Code of Professional Conduct.
Currently, equine dental procedures can be performed by unregulated equine dental technicians (EDTs) with varying levels of training and/or experience. There is no governing body in New Zealand that regulates the training, qualification or accreditation of EDTs.
The NZVA recommends that veterinarians follow the guidelines contained in this position statement and in the NZVA Position Statement 10i – Supervision of Equine Dental Technicians. Co-operation with competent EDTs is therefore facilitated and encouraged, whilst ensuring the welfare of horses under the care of veterinarians is optimised.
Equine dental procedures require the appropriate use of sedatives, anaesthetic agents, pain management pharmaceuticals, antimicrobials, and other pharmaceuticals to maximise the comfort and safety of the horse and operator, and ensure the successful outcome of the procedure. A comprehensive knowledge of the aetiology of dental disease is necessary to properly communicate prognosis and preventive procedures to clients.
The NZVA acknowledges the importance of the Veterinarian-Client-Patient Relationship (VCPR) as a necessary component of the communication process to help define client expectations and ensure the success of any dental procedure.
From May 2020, section 16 of the Animal Welfare Act 1999, will use the following criteria to determine if a procedure is a significant surgical procedure:
“(a) whether the procedure has the potential to:
(i) cause significant pain or distress; or
(ii) cause serious or lasting harm, or loss of function, if not carried out by a veterinarian in accordance with recognised professional standards; and
(b) the nature of the procedure, including whether this involves:
(i) a surgical or operative procedure below the surface of the skin or mucous membranes, or below the gingival margin of teeth; or
(ii) physical interference with sensitive soft tissue or bone structure; or
(iii) significant loss of tissue or loss of significant tissue.”
Using these criteria, the NZVA believes most equine dentistry procedures are considered to be significant surgical procedures, and must only be performed by a veterinarian. Veterinarians should refer to the NZVA Equine Dentistry Procedure Category List (refer to NZVA Position Statement 10i – Supervision of Equine Dental Technicians) to understand fully which procedures can be performed by EDTs (with or without direct and continuous veterinary supervision).
Using these criteria, the NZVA position is that equine dental procedures that should only be undertaken by a veterinarian include:
- Reduction of overgrowths greater than 3mm.
- All tooth extractions (including removal of wolf teeth).
- Widening of diastemata.
- Endodontics and all other dental restoration procedures.
- Treatment of periodontal disease.
Using these criteria, the NZVA’s position is that equine dental procedures that may be undertaken by non-veterinary persons are:
- The removal of sharp enamel points or small dental overgrowths (maximum 3mm reduction) using manual rasps only.
- The removal of loose teeth or deciduous caps with no periodontal attachment without the use of tools.
The international situation
In many states in the United States of America, equine dentistry is considered an act of veterinary medicine and non-veterinary dental providers have been prosecuted.
American Association of Equine Practitioners
“Any surgical procedure of the head or oral cavity; the administration or prescription of sedatives, tranquilizers, analgesics or anaesthetics; procedures which are invasive of the tissues of the oral cavity including, but not limited to, removal of sharp enamel points, treatment of malocclusions of premolars, molars, and incisors; extraction of damaged or diseased teeth; treatment of diseased teeth via restorations and endodontic procedures; periodontal and orthodontic treatments; and dental radiography are veterinary dental procedures and should be performed by a licensed veterinarian”
At present in Britain, all diagnostic and treatment procedures in the horse’s mouth are considered to be ”Acts of Veterinary Surgery” under the Veterinary Surgeons Act 1966, and are regulated by the RCVS. The British Equine Veterinary Association states that “these laws are designed to protect animals (including equidae) against mutilation by inappropriately qualified individuals, to regulate the behaviour of Veterinary Surgeons and to maintain ethical and professional standards.” In Britain, appropriately trained and regulated EDTs are permitted to undertake some equine dental procedures.
The Canadian Veterinary Medical Association (CVMA) states that performing dentistry on animals falls within the scope of practice of Veterinary Medicine. “Veterinary Dentistry involves every aspect of oral health care procedures including but not limited to the cleaning, adjustment, filing, extraction or repair of teeth and treatment of or surgery to related structures” (CVMA,2011).
CVMA Policy Statement on Veterinary Dentistry
“Equine dentistry is a component of veterinary practice that requires diagnosis and treatment of disease and demands extensive knowledge of anatomy, anaesthesiology, pharmacology, physiology, pathology, radiology, neurology, medicine, and surgery; all of which are part of a veterinarian's training.”
Performance of equine dentistry requires an understanding of the pathogenesis of dental diseases in horses. This understanding is essential to make informed judgments regarding treatment. Veterinarians are uniquely qualified to diagnose equine dental disease and address unexpected health conditions that may arise during dental examinations and procedures, and to prescribe follow-up care.
The Australian Veterinary Association believes “All dental procedures on horses and related species should be performed only by registered veterinarians and be supported by evidenced-based medicine.”
- College of Veterinarians of British Columbia – Veterinarians Act, 2010.
- American Association of Equine Practitioners – AAEP Policy Statement on Equine Dentistry 2012.
- Canadian Veterinary Medical Association – CVMA Veterinary Dentistry Policy Statement, July 29, 2011.
- New Zealand Animal Welfare Act 1999 – Section 16 Surgical Procedures.
- Royal College of Veterinary Scientists – Veterinarians Act 1966, Acts of Veterinary Surgery.
- Australian Veterinary Association – Policy Statement Equine Dentistry, 2008.