How crucial is semantics in regulation?

Cat Edney explores how unclear regulatory language and ambiguous semantics are impacting dental therapists.

Cat Edney explores how unclear regulatory language and semantic ambiguity are impacting dental therapists – especially around scope of practice and chairside support.

Over my twenty years of seeing patients, and more recently spending time with multiple thought leaders in dentistry, I have come to the realisation that making yourself fully understood is an absolutely essential part of this profession.

Our consenting process relies on it. But also, within regulation, making yourself fully understood is becoming more of an issue that needs fully addressing.

This month, I want to highlight two areas in which semantics is having a seismic impact on dental therapists nationwide: chairside assistance and scope of practice.

GDC determination: landmark ruling for dental hygienists and therapists

In dentistry, professional standards are the backbone of safe and effective patient care. A recent ruling by the General Dental Council (GDC) has put a spotlight on the necessity of chairside assistance during dental procedures—an issue that directly impacts dental hygienists and therapists, who are often expected to work alone.

The GDC’s Professional Conduct Committee recently reviewed a case in which a dentist found guilty of treating patients without the support of a registered dental nurse or trainee between 2016 and 2020. This was deemed a breach of GDC Standard 6.2.2, which states that clinicians must work with another appropriately trained dental team member during patient treatment – except in exceptional circumstances such as out-of-hours emergencies or public health programs.

For dental hygienists and therapists, this determination is particularly significant. It clearly establishes that the requirement for chairside assistance applies to all dental professionals, not just dentists.

The reality for hygienists and therapists

For years, many dental hygienists and therapists – especially in NHS settings and corporate dentistry – have been routinely scheduled to work without chairside assistance. In some cases, this has been viewed as a cost-saving measure by employers. However, this new ruling raises serious legal and ethical concerns around whether such practices are compliant with GDC standards.

Unlike their dentist colleagues, hygienists and therapists often have little control over staffing levels, despite performing complex procedures such as periodontal treatment, restorations, and local anaesthetic administration. The GDC’s determination makes it clear: working alone should not be the norm.

The recently published white paper on the issue, ‘A Perspective From the British Society of Dental Hygiene and Therapy Members Regarding the Need for Clinical Support by a Dental Nurse’, published in the International Journal of Dental Hygiene, highlights the varied positions taken by members of the society. It also points to a number of papers that cite the challenges faced by both professions when trying to uphold the GDC standards.

Why chairside assistance matters

Chairside support is not just about convenience—it’s about patient safety, efficiency and professional compliance. Here’s why it’s crucial:

Infection control and efficiency: many hygiene and therapy procedures involve aerosol-generating equipment. A dental nurse helps with aspiration, retraction and maintaining a dry field, improving both efficiency and infection control
Medical emergencies: in the event of an adverse event, having another trained professional present could be life-saving
Patient experience: a dental nurse can reassure and communicate with anxious patients, improving the overall experience, but also contribute to the care of patients, with better teamwork, efficiency and a streamlined patient journey
Regulatory compliance: the GDC’s ruling now reinforces that Standard 6.2.2 applies to all clinicians, not just dentists.

What this means for employers and commissioners

This ruling doesn’t just affect individual clinicians – it also places a responsibility on dental employers and commissioners (including NHS trusts, corporate dental groups and practice owners) to ensure staffing levels comply with professional standards.

If an employer routinely expects hygienists or therapists to work without chairside support, they could now be seen as contributing to professional misconduct – potentially exposing both the clinician and the practice to regulatory action.

For clinicians working within NHS contracts or corporate settings, this ruling provides a stronger basis to request dental nursing support, particularly if it has previously been denied.

Clarity is key: scope of practice needs to evolve

The GDC standards give guidance as to how they should be followed, but there is ongoing ambiguity surrounding scope of practice (SOP). Dentistry is a constantly evolving profession; with innovations in digital technology and shifts in how dental care is delivered transforming the landscape significantly in recent years.

However, the lack of transformation of the SOP is a concern. The new SOP document has been promised for some time, yet once published one has to wonder if it may already be outdated.

Although the GDC scope of practice specifically mentions that it is not an exhaustive list of duties registrants may undertake, indemnity providers do seem to take it this way. In addition, with the confusion and differing interpretation of SOP not only limited to differing opinion between indemnifiers, it seems to be that registrants also receive differing advice from the same indemnifier.

The current lack of clarity has led to constraints that prevent DCPs from evolving alongside the profession. A notable example is the uncertainty around whether dental therapists can carry out interproximal reduction (IPR) as part of clear aligner treatment. Some indemnity providers claim it falls outside their scope, yet IPR involves the removal of enamel, a task therapists are already trained to do when placing direct restorations. One would wonder why a dental therapist couldn’t train in this skill.

Held back from our full potential

Similarly for dental hygienists, the provision of resin infiltration treatment – a minimally invasive technique to treat early enamel lesions – aligns closely with fissure sealants, which are explicitly listed within their scope. Yet, the ambiguity persists, leaving clinicians unsure and potentially underutilised.

The GDC’s ‘Standards for the Dental Team’ outlines the professional responsibilities of registrants, but does little to support clinicians in interpreting or expanding their scope. Without clearer, more dynamic guidance that reflects current practice and innovation, we risk holding back skilled professionals from working to their full potential.

What’s needed is a more flexible, regularly reviewed and updated SOP guidance – one that ensures the whole dental team can grow with the profession and continue delivering safe, modern and effective care.

Catch up with Cat’s previous columns:

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