Grace period

IAED certification is accepted to qualify for registration in Virginia.

Therefore the rules and regulations of IAED certification should be taken into consideration when you determine the grace period.  IAED require 250 horses to have been done by the candidate.  They also require you to have been a member for 9 months before certification.  Another factor is that they only do the certification once every 9 months.

We propose that EQDT’s are allowed to work under supervision of registered EQDT or veterinarian, until IAED certified with no time limit.

50% equine business veterinarian reference

Currently EQDT’s are required to get two reference letters from veterinarians who has at least 50 % equine business.  Why 50%?  This requirement seems arbitrary and capricious.  Having a practice with at least 50% equine business, that does not mean that the veterinarian knows about equine dentistry.   On the other hand, a veterinarian with only 10% equine business may be very knowledgeable about equine dentistry.

Therefore any veterinarian with some equine business, should be acceptable as a reference for the applicants’ competency and moral character.

Registered EQDT required to work under direct supervision by veterinarian when using motorized equipment

If an EQDT has IAED certification and/or 5 years experience plus two veterinarians’ saying that you are competent using hand tools and power tools, then why do registered EQDT’s have to be supervised by a veterinarian when they use motorized equipment?

On the other hand, LVT’s with little or no experience in equine dentistry can lawfully work on horses’ teeth with power tools with veterinary supervision, but again, this veterinarian can be even a small animal veterinarian with little or no equine dentistry knowledge.

We propose that if EQDT's are IAED certified, or have 5 years experience, they are allowed to do motorized equine dentistry without direct supervision by a veterinarian.

LVT’s  working on horses’ teeth without same qualifications as EQDT

The current LVT programs has very limited education in equine dentistry.

LVT’s are allowed to work under direct supervision, but that could be any veterinarian, even small animal veterinarians, who might have very little knowledge about equine dentistry.

If the Law is going to require EQDT’s to pass a certification in order to work on horses’ teeth, then all people that want to work on horses’ teeth, should demonstrate their abilities,  including veterinarians, LVT, etc.

The law and regulations at the moment is discriminatory.  If they want to regulate equine dentistry as a profession, then the law must apply to all participants equally, EQDT’s, veterinarians and LVT’s

Signed:  Hanina Hyde, Meredith Barlow, Myles Hopton, Amanda Bourne, Lisa Jarrell, Jill Cathey, Stephanie Suprenant, Hubert Davy, Erica Beck, Raymond Hyde, Robin Army, Lisa Murphy, Ron Haines, Amanda Compton

TO WHOM IT MAY CONCERN:

In addition to the proposed changes made by "Equine Dental Technicians"- that I signed and support. I would like to add a few that we left out in that comment.

 Wolf Teeth Removal

The current law states that a veterinarian must be present when caps (deciduous teeth) and wolf teeth are removed. The routine extraction of wolf teeth is a very simple procedure that often times takes less than 5 minutes. In rare instances the palatine artery can be struck, even by properly trained professional, causing profuse bleeding. Due to the location of these teeth, the bleeding can easily be stopped by simply applying pressure. Trained professionals know this, and are capable of doing so. If veterinary assistance were needed, then the owner's veterinarian could be called out. Arizona state law simply requires indirect supervision for all dental procedures meaning that a veterinarian needs to be available by phone when dentistry is to be performed.

Cheek Teeth Removal

Many veterinarians employ dental technicians to do the "more difficult extractions" that would previously have been sent to a referal clinic  to be removed under general anesthesia. Young horses with diseased cheek teeth have historically had to undergo serious surgeries with months of recovery. With proper education and training dental technicians can now remove many of these teeth using standing sedation (*administered or prescribed by a veterinarian). This allows the horse for a quicker recovery with out the dangerous complications associated with general anesthesia.

It is logical to require that a veterinarian be present for these more difficult extractions as they often involve nerve blocks, and after care such as antibiotics that the veterinarian would need to prescribe. However, since many veterinarians do not even offer such services or even own the equipment it is unreasonable to take this out of our scope of practice.

I beleive that horse owners should have the right to employ dental technicians to practice equine dentistry in its full scope, just as they are able to employ farriers.

Thank you,

Meredith Barlow, EqDT

§ 54.1-3806

C. It shall be unlawful for any person not holding a current and valid registration as an equine dental technician or a current and valid license as a veterinarian to perform the following duties:

3. Any other task restricted pursuant to regulations promulgated by the Board.

Notwithstanding the foregoing, no equine dental technician shall administer any sedative, tranquilizer, analgesic, prescription medication, or other drug under any circumstances.

I do believe that this restriction is contrary to other veterinary laws already in place that allows a veterinarian to appoint someone to help them administer of drugs (analgesic, tranquilizer, prescription, non-prescription, etc.).   According to this Equine Dental Technican law, the EQDT cannot even give their own horse a wormer, analgesic, tranquilizer,etc.  Why would you single EQDT's out with this restriction?

If an EQDT wants to give their horse a tranquilizer or sedative to clip him or for the farrier, they would not be allowed by the current EQDT Law to do so. 

I do believe that the wording should be changed so it makes more sense.  There are already laws in place that regulate the administering of medication to animals and there is no need to include this in the EQDT law.