Regulation Without Representation

The Boston Red Sox have won the World Series and thrown off the Bambino Jinx. In 1773, just a bit before there even was baseball, there was a Tea Party in Beantown. Taxation without representation was to become a battle cry that would carry through to the revolutionary war of 1776. FDA, OSHA, IRS and all of the other acronyms that guide us and the production, sale, distribution and taxation of our dental laboratory industry throughout our business cycles is stepping a bit closer to regulating our industry without our representation. The Bostonians of 1773 were not invited or even allowed to participate in their regulation and taxation. They were but a colony of England, a place to sell and distribute his majesty’s goods and service for the benefit of the homeland. We, however, have a choice.

There are still less than 500 Certified Dental Labs in the United States out of more than 15,000 custom manufacturers of medical devices for dentistry. I use that term to describe us because we will need to get used to it. The FDA has recognized that what we do requires a set of manufacturing, processing, service and policy standards that are similar to other medical device manufacturers. This is not necessarily a bad thing. We can elect to step in and represent ourselves as the story unfolds. OSHA, DAMAS, CDL status, and even licensure are available regionally as well as nationally to help us professionalize and differentiate us from the unregulated cottage industries. We have a real choice. We can partner with dentistry. We can step in and fill the void that current dental education leaves regarding laboratory techniques (The Profession of Dentistry and Dental Lab Technology; Improving the Interface). We can choose to define the policies and procedures as a custom manufacturer of medical devices and insure quality competencies through self-guidance and voluntary regulation, certification and perhaps even licensure. Or we can stand still, pat, mute and watch others do this to us.  Not for us, but to us.

What a great first step toward more parity professionally with dentistry than to certify technicians and the facilities they work in. I can’t think of any other health care related service provider that is like we are in 46 states. Pharmacies that fill prescriptions have licensed professionals, policies and procedures that oversee their activities. So to do hospitals, clinics, prosthetic manufacturers, drug plants and distributors, opticians, massage therapists and the like. We must step forward or be left behind. Not left behind from regulation, but left behind in the voice for governance. We can seize a moment in time like this to professionalize and partner with another profession that needs a strong cooperative relationship with our industry. We can guide our future to a better place by helping to create it. I am proud to work with Certified Dental Laboratories and Certified Dental Technicians in my practice of dentistry. I educate my patients and colleagues. I stand (sit actually typing) before you and challenge us to grow. Change is inevitable. Growth is optional. Change is coming indeed. What we make or do with it is up to us.