Position statement on GDC registration requirements for oral and maxillofacial surgeons and other healthcare professionals regulated by statute
The legal framework around exemption from the requirement for GDC registration
- The setting in which an activity is undertaken (e.g hospital department, private clinic) does not matter when considering whether it is a medical task.
- The inclusion of an activity within a non-dental professional’s curriculum or scope of practice does not in itself determine whether that activity is a medical task.
Application of the framework to oral and maxillofacial surgeons
12. Whilst an oral and maxillofacial surgeon may be able to rely on the medical task exemption for activities within their OMFS work, the exemption does not apply to everything that an oral and maxillofacial surgeon may choose to do outside their medical practice. Oral and maxillofacial surgeons are trained in a wide variety of dental techniques and may choose to practise certain dental techniques outside their role as an oral and maxillofacial surgeon. If that activity is not undertaken as part of a medical task, it is legally dentistry and GDC registration is required (see practical examples).
Application of the framework to other healthcare professionals
16. Professionals must meet the CPD and/or revalidation requirements of each regulator they are registered with. The GDC’s CPD requirements do not vary for its registrants if they are also registered with another regulator.
The following examples are designed to support professionals consider how they may apply their judgement to determine whether they could rely on the medical task exemption. In practice this will always depend on the particular scenario and case specific
Please note that because care settings are not relevant to the requirement for dual registration, they have not been specified. The examples apply in any care setting and for any type of care (e.g. NHS or private care).
- As part of a wider course of medical clinical care, an oral and maxillofacial surgeon carries out an extraction on a patient. They do not need GDC registration as the extraction has been undertaken as a medical task.
- Unexpected medical complications arise whilst a dentist is undertaking an extraction on a patient, so the dentist hands over care to an oral and maxillofacial surgeon mid-procedure. The oral and maxillofacial surgeon does not need GDC registration as the ongoing clinical care is delivered as a medical task.
- An oral and maxillofacial surgeon operates an implant clinic. Dual registration will be required if implant procedures are not undertaken as part of wider medical clinical care.
- A dentist refers a patient to an oral and maxillofacial surgeon when specialist OMFS practice is needed for their care. The oral and maxillofacial surgeon does not require dual registration to manage the referred patient.
An oral and maxillofacial surgeon performs restorative dental procedures which are not part of wider medical clinical care. GDC registration is required.
- An unregistered dental student is observing an oral and maxillofacial surgeon as part of their training. The student does not need to be supervised in that setting by a registered dental professional, as they are not providing dental treatment to patients.
- An unregistered dental student is undertaking dental practice under the joint supervision of a GDC registered dental professional and a GMC registered oral and maxillofacial surgeon. The oral and maxillofacial surgeon does not need dual registration because the legal supervision requirement for the unregistered student has been met by the GDC registered supervisor.
- An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), plans a surgical procedure, assists with a surgical device in theatre, and makes or fits a facial prosthesis or obturator that may include artificial teeth. They do not need GDC registration as these activities are delivered as medical tasks.
- An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), makes dentures for a patient. If these dentures are not delivered as part of wider clinical care (e.g. as part of a multidisciplinary care plan), GDC registration will be required.
- An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), is directed by an oral and maxillofacial surgeon to take an intra-oral impression for a maxillary obturator. They do not require GDC registration as the impression is delivered as part of wider medical clinical care.
- Am I registered with a statutory regulator?
- Am I appropriately qualified?
- Does the specific dental activity take place as part of the delivery of wider clinical care?
30 January 2023
 The practice of dentistry is defined in section 37 of the Dentists Act 1984 where it states: 'the practice of dentistry shall be deemed to include the performance of any such operation and the giving of any such treatment, advice or attendance as is usually performed or given by dentists; and any person who performs any operation or gives any treatment, advice or attendance on or to any person as preparatory to or for the purpose of or in connection with the fitting, insertion or fixing of dentures, artificial teeth or other dental appliances shall be deemed to have practised dentistry'.
 The nine statutory health regulators are: General Dental Council, General Medical Council, Nursing and Midwifery Council, General Optical Council, General Pharmaceutical Council, General Osteopathic Council, General Chiropractic Council, Health and Care Professions Council, Pharmaceutical Society of Northern Ireland. Collectively they register many professions who may be involved in surgery and emergency care related to the mouth such as doctors, nurses, paramedics, and clinical scientists.
 Dentists Act 1984 (Amendment) Order 2005 (SI 2005 No. 2011)
 Under section 39 of the Dentists Act 1984 it is an offence for an individual to use any of the following titles, either alone or in combination with any other word, unless they are registered with the GDC: dentist, dental surgeon, dental practitioner, clinical dental technician, dental hygienist, dental nurse, dental technician, dental therapist, orthodontic therapist.