Bureau of Professional and Occupational Affairs

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

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