| January 24, 2005 |
| Dr. Newton Gordon, President |
| Dental Board of California |
| 1432 Howe Avenue, Suite 85-B |
| Sacramento, CA, 95825 |
| Re: Regulatory Proposal to Amend Section 1064 Title 16 CCR - Opposition & Questions |
| Dear Dr. Gordon and Board Members: |
| The Council of Acupuncture and Oriental Medicine Associations has advocated for the Acupuncturist |
| profession for nearly twenty years, developing and promoting standards of practice and training, |
| sponsoring legislation, and commenting on proposed regulations. We would respectfully like to express |
| our opposition to your proposed reduction in acupuncture training for dentists, based upon the inadequacy |
| of evidence available to us from the public record. We would like to pose some questions to the Dental |
| Board about the “safe and effective” practice of acupuncture by dentists, and your proposed regulatory |
| changes. |
| 1. How Was the 80-hour Standard Established? |
| In a letter from Dr. Pogrel to the Dental Board, dated April 15, 2004, Dr. Pogrel suggests that the “80 |
| hours may have been a somewhat political and arbitrary number of hours.” We are curious as to the |
| basis for this comment, and would like to know more of the history. |
| Question 1: Has the Dental Board reviewed the criteria used for the establishment of the Section |
| 1064 80-hour standard in 1988, including any testimony, surveys, or meeting minutes? Are those |
| documents available for the public to review? |
| 2. Has the Board Conducted a Survey? |
| In the minutes of the Anesthesia Committee meeting on November 4, 2004, Dr. Goddard testified that |
| “the main thrust of acupuncture [practiced by dentists] is for TMJ dysfunction and associated muscular |
| problems,” implying that this should be the focus of acupuncture training for dentists, and that other |
| applications and techniques are less important to teach. It would seem that the Dental Board would wish |
| to substantiate this claim before taking further action. |
| Question #2: Considering that the request for a reduction in training standards comes from a |
| interested party, namely a provider of dental education, has the Dental Board conducted an |
| independent survey of its licensees to determine the prevalence of acupuncture practiced by |
| dentists, what it is effectively used for, and other related questions, or is the Dental Board aware of |
| any similar surveys conducted by other parties that would be useful in setting new standards for |
| such practice? If no such surveys exist, does the Dental Board plan to conduct such a survey |
| itself? |
| 3. Have Competencies Been Verified? |
| In a letter to the Dental Board, dated September 28, 2004, Dr. Goddard claims that his students have |
| “mastered safe and effective acupuncture for dentistry” after fifteen hours of training, as evidenced |
| by passing a final exam. |
| Question 3: Has the Dental Board verified that Dr. Goddard’s students have “mastered” |
| acupuncture for dentistry after fifteen hours of training, via third-party examination or |
| certification, patient affidavits, safety records, or other means of verification? |
| 4. Is an 80-Hour Course from 1997 Useful for Comparison Purposes? |
| In a letter to UCSF, dated July 17, 1997, the Dental Board approved an 80-hour course in “acupuncture |
| and the treatment of orofacial pain” to be taught at UCSF, stating that the course “meets the criteria” |
| of Section 4947 of the Business and Professions Code (the exemption). The letter does NOT state that |
| the course meets the criteria of Section 1064 of the Dental regulations. The title of that 24-session course, |
| “Acupuncture / Orofacial Pain Certification Course,” and its schedule clearly indicate that it was a |
| combination course, less than fifty percent of which appeared to be acupuncture-specific. In a letter to |
| the Dental Board, dated September 28, 2004, Dr. Goddard proposes reducing the 80-hour requirement to |
| 24 hours, arguing that the “complicated study of Traditional Chinese Medicine” is no longer necessary, as |
| it was thought in 1988, when the Dental Board adopted Section 1064. Yet, in UCSF’s original 80-hour |
| course in acupuncture, only four hours were dedicated to “acupuncture theory,” and it is only being |
| proposed to reduce that subject by one hour. |
| Therefore, it would seem that comparing the UCSF 80-hour course in “acupuncture and orofacial pain” to |
| the 80-hour requirement of Section 1064 is not a valid comparison and should not be used as an argument |
| for reducing the hours in Section 1064. |
| Question #4: Considering that the 80-hour UCSF course used for comparison was a combined |
| course in orofacial pain and acupuncture, has the Dental Board reviewed approved 80-hour |
| courses in acupuncture for dentistry that meet the criteria of Section 1064 and compared them with |
| the newly proposed 24-hour standard? |
| 5. Are Non-Dental Area Injections and Acupuncture Allowed? |
| The curriculum outlines show that Dr. Goddard’s students are taught to needle points in the hands, arms, |
| legs, and feet. We have no doubts that dentists are extremely well trained in the safe insertion of needles |
| in the mouth, jaw, and face. However, inserting needles in other locations does not seem to fall within any |
| aspect of a dentist’s core training, and we are unclear as to the Dental Board’s policies regarding |
| injections by dentists in areas other than the jaw and face. It would seem that inserting acupuncture |
| needles in non-dental areas would fall under the same guidelines and standards of practice for dentists as |
| would providing injections. |
| Question #5: What are the Dental Board’s policies regarding the regulation of training and |
| practice for injections by dentists in locations other than the mouth, jaw, and related structures? |
| Are these policies consistent with the Dental Board’s policies regarding the regulation of the |
| insertion of acupuncture needles in non-dental areas by dentists? |
| 6. Is Training in Acupuncture-Related Techniques Adequate? |
| Section 1064 specifically requires that moxibustion and electroacupuncture be taught in any certification |
| course in acupuncture for dentists. Teaching the basics of safe application of moxibustion and |
| electroacupuncture can take dozens of hours in themselves, let alone treating specific conditions with any |
| efficacy. It is not clear where these clinical skills are adequately taught in the 80-hour course, and they |
| are entirely absent from the 24-hour course description. |
| Question #6: What standard is the Dental Board applying in establishing either its 80-hour |
| standard, or the newly proposed 24-hour standard, that assures that its approved courses |
| adequately teach the safe and effective clinical application of moxibustion, electroacupuncture, |
| and other acupuncture-related techniques to dentistry? |
| 7. What Acupuncture Training is Taught in Standard Dental Training? |
| The recent request for the reduction in hours by Dr. Goddard is partly based upon the claim that there is |
| now a 56-hour duplication between the 1997 board-approved course in acupuncture and orofacial pain |
| and the core curriculum currently being taught at dental schools. |
| Question #7: Has the curriculum for approved DDS educational programs expanded since 1997 to |
| specifically include the 56 hours of content that Dr. Goddard is requesting be eliminated from the |
| certification course in orofacial pain and acupuncture? |
| 8. How Were Points and Non-Dental Conditions Selected? |
| After reviewing the course descriptions for the acupuncture training programs for dentists, many |
| acupuncturists have wondered about the selection of points being taught in these courses, especially as |
| there may be dozens of “Ashi” points that are mentioned, but not itemized, in the course descriptions, and |
| these may be used to treat non-dental conditions. There are also questions about the described use of |
| acupuncture for non-dental conditions, such as for myofascial pain, fibromyalgia, and headache pain. |
| Question #8: What is the Dental Board’s policy towards the treatment of non-dental conditions by |
| dentists? |
| We hope that our questions result in a more insightful, evidence-based, and valid standard for training for |
| dentists who legitimately wish to enhance their practices with acupuncture. As advocates for the practice |
| of acupuncture, we especially desire the establishment of standards that are neither political nor arbitrary |
| in their basis, but are based upon solid evidence and expert opinion. We look forward to participating in |
| further discussions on this subject and to your responses to our inquiries. |
| Should you have any further questions, please feel free to contact us. |
| Sincerely, |
| Michelle Lau, LAc, PhD, President |
| Brian C. Fennen, L.Ac, QME, OBT, Executive Director |