Federation of European Dental Competent Authorities and Regulators

FEDCAR

L’Association se fixe les objectifs suivants : Promouvoir la sécurité des patients dentaires en Europe en facilitant le partage d’informations et de bonnes pratiques en matière de réglementation des professionnels dentaires, et en développant des points de vues et des approches similaires concernant les nouvelles initiatives et la législation au niveau européen; Promouvoir un niveau de qualité élevé pour les soins bucco-dentaires en Europe; Contribuer à faciliter de façon sûre la mobilité des professionnels dentaires au sein de l’Europe. (article 4 des statuts)

Lobbying Activity

Response to Professional qualifications recognition of nurses, pharmacists and dental practitioners - training requirements update

9 Feb 2024

FEDCAR is the European Federation of Dental Regulators. It is composed of 15 private and public bodies with delegated powers to regulate dental professions. We thank the Commission for the opportunity in the last stages of the legislative process to give an opinion on this draft proposal of delegated act. We welcome the proposed 6 new items, the 2 reformulations and the new digital competence and we understand they are the (lowest) common denominators to the current training in place in the 27 Member States. We have one suggestion. It regards the clinical training listed in Annex 5.3.1 that in our view should be updated. CLINICAL TRAINING IN DENTISTRY Clinical education refers to the training of students with patients. It importantly comes in addition to the theoretical and practical training so that on day 1 the newly-graduated dentist can safely treat the patients teeth, mouth, jaws and associated tissues. SCIENTIFIC & TECHNOLOGICAL EVOLUTION The clinical competence of a dental practitioner is one of the minimum knowledge and skills to be acquired during training, as expected by Directive 2005/36 (Art.34(3)(e). The current wording of Annex 5.3.1 dates back to 1978 (Directive 78/687/CE of 25/7/1978 replicated in Directive 2005/36). In the meantime the need for clinical training has gained in volume and importance given the complexity of dental surgery in the XXIst century. Access, duration and content of clinical training varies a lot today through Member States (see evidence and data in sources 1 and 2 and 3). An updating of the requirements for dental training without take consideration this development would not reflect the scientific and technological evolution requested by the Legislator (Article 34(2)). PROPOSAL The importance of a further emphasis on clinical training in Annex 5.3.1 was many times highlighted by stakeholders during a recorded workshop organized by Spark Legal Network on 29 June 2021 ; unfortunately this key feedback was not reported in either the final report or in its recommendations. We propose to reflect this evolution by the following statement placed at the end of Annex 5.3.1. : « The theoretical and practical training must be balanced and coordinated with the clinical training required for subjects directly related to dentistry, so that the knowledge and experience referred to in this Annex are adequately acquired at the end of the training and enable the practitioners to carry out all their duties at the point of graduation. Clinical teaching is carried out with patients under appropriate supervision ». See the enclosed document for i) the proposals justifications compared to the EU Commissions mandate and ii) the sources.
Read full response