HEALTH PROFESSIONS COUNCIL
RECOMMENDATIONS ON THE
DESIGNATION OF OCCUPATIONAL THERAPY

This report is in response to an application by the British Columbia Society of Occupational Therapists for designation under the Health Professions Act (R.S.B.C. 1979, c. 162.7). Under this Act, the Health Professions Council is a nine person advisory body appointed by the Government of British Columbia to make recommendations to the Minister of Health and Minster Responsible for Seniors about the regulation of health professions. This report is the result of an investigation of the profession of occupational therapy by a three member panel of the Health Professions Council.

EXECUTIVE SUMMARY

The Health Professions Council has determined that: the practice of occupational therapy falls within the definition of a "health profession" as defined in the Health Professions Act (the Act) and there is sufficient risk of harm in the practice of this health profession that it would be in the public interest to designate it under the Act. In addition, the Council applied the facultative public interest criteria set out in section 5(2) of the Health Professions Regulation under the Act (the Regulation), and found that these criteria support designation of the profession of occupational therapy in the public interest.

The Council recommends that a College of Occupational Therapists be established and that the title "occupational therapist" be reserved for members of the College. The reservation of the title will assure the public that those who use it meet the requirements of the College in qualifications, preparation, and practice.

With respect to scope of practice, the Council recommends that the services which may be performed by occupational therapists are the assessment and remediation of occupational performance chanllenges in order to develop, restore, maintain, and enhance the function of clients of all ages. The Council does not recommend any reserved acts be designated for occupational therapy.

Baccalaureate degree programs are in place and qualifications and standards of practice are well defined. The British Columbia Society of Occupational Therapists, established in 1945, represents the vast majority of practitioners. Indications are that a College established under the Act would be administratively and financially viable.

It is the Council's mandate to define appropriate scopes of practice, including narrrowly defined reserved acts, to foster interdisciplinary practice and to promote safe options for the public. Some of the services of occupational therapists are also provided by or with other qualified health professionals. The public will be adequately protected by seeking the services of an occupational therapist who is practising within the provisions established by the College.

I. APPLICATION AND PROCESS OF INVESTIGATION

In Canada, only British Columbia, the Yukon, and the Northwest Territories have no established mechanisms to regulate the practice of occupational therapy. In all other provinces, occupational therapists have a separate professional act. In Ontario occupational therapists are one of the regulated health professions under the Regulated Health Professions Act.

An application, accompanied by the required fee, was submitted to the Health Professions Council on March 26, 1993 by the British Columbia Society of Occupational Therapists (the applicant) for the designation of occupational therapy as a health profession under the Act. This society represents 868, or 89 per cent, of the estimated 972 occupational therapists in British Columbia.

The applicant was incorporated as a society under the Society Act in 1945 and has served as the professional organization for registered occupational therapists since that date.

Pursuant to s. 7(3)(c) of the Act, an investigation of the practice of occupational therapy was undertaken by the Council. The investigation involved:

• consultation with related professions, consumer groups, and other interested parties. A list of the organizations to which letters of consultation were sent is included in Appendix A.

• a review of the practice of occupational therapy and its regulation in other jurisdictions. Provincial occupational therapy regulations were compiled and can be found in Appendix B;

• an informal public hearing which was held on October 20, 1995 in Vancouver. Participants in this hearing are listed in Appendix C.

II. STATEMENT OF ISSUES

During the investigation, the three main issues addressed by the Council were:

1) the extent to which the practice of occupational therapy may involve a risk of physical, mental, or emotional harm to the health, safety, or well being of the public as specified in Health Professions Regulation, 5(1);

2) the scope of practice appropriate for occupational therapists practising in British Columbia;

3) reserved acts, if any, that should be granted to the profession.

III. RECOMMENDATIONS

The Health Professions Council recommends to the Minister of Health and Minister Responsible for Seniors that:

1) occupational therapy be designated as a health profession under the Act;

2) the college established for the health profession be named the College of Occupational Therapists of British Columbia;

3) the title "occupational therapist" be reserved exclusively for registrants of the College of Occupational Therapists;

4) the services which may be performed by occupational therapists are the assessment and remediation of occupational performance challenges in order to develop, restore, maintain and enhance the function of clients of all ages. Occupational performance refers to the ability of a person to safely and effectively do the everyday activities necessary for self care, productivity and leisure; and

5) no reserved acts be granted to the profession of occupational therapy.

IV. RATIONALE FOR THE RECOMMENDATIONS

A. DESIGNATION AS A HEALTH PROFESSION

In order to recommend the designation of occupational therapy under the Act, the Council must determine that: 1) occupational therapy falls within the definition of health profession as set out in Section 1 of the Act; and (2) designation is in the public interest pursuant to Section 5 of the Regulations under the Act.

1. Definition

The Act (s.1) defines a health profession as ". . . . a profession in which a person exercises skill or judgment or provides a service related to (a) the preservation or improvement of the health of individuals, or (b) the treatment or care of individuals who are injured, sick, disabled or infirm."

The review of the services performed by occupational therapists satisfied the Council that occupational therapy falls within this definition.

According to information provided by the applicant, and supported by comments at an informal hearing, occupational therapists utilize specific techniques and technology which require expert knowledge and judgment to obtain optimum therapeutic results. Such expert knowledge and judgment are necessary to avoid further deterioration in persons who are compromised either physically or mentally and at risk if services are not performed by a qualified occupational therapist. Support for this position was provided by the Canadian Association of Occupational Therapists, the American Occupational Therapy Association, and the College of Physical Therapists of B.C., and was unopposed by any submission made to the Council.

2. Public Interest Criteria

a. Risk of Harm

Pursuant to Section 5(1) of the Regulations under the Act, the Council must consider the extent to which the practice of a health profession may involve a risk of physical, mental or emotional harm to the health, safety or well being of the public, having regard to:

s. 5(1)(a) the services performed by practitioners of the health profession

The applicant submitted, in part 12 of the application for designation, that

Occupational therapists offer a broad range of assessment and intervention services to individuals and groups from birth to old age. Occupational therapists specialize in assessing and identifying problems, and in planning and providing intervention to prevent, remedy or adapt to problems in occupational performance. OT practice is grounded in theories related to occupation and functional performance.

...The following...lists services and examples of how they are offered.

• In a special care nursery, the occupational therapist uses brief tests of sensorimotor and neurobehavioural performance to screen infants for sensory or motor impairment or potential developmental delays... <

• In an acute care hospital the occupational therapist, working with a woman who has had a stroke, assesses her ability to carry out self care tasks such as eating, dressing, grooming and using the toilet. Later, in a rehabilitation setting, the occupational therapist will evaluate this woman's ability to do meaningful homemaking, work and leisure tasks, including an evaluation of the home and community environment to which the woman will return on discharge...

• The occupational therapist consulting to a group home for young adults with multiple physical handicaps develops a plan for their new independent living situation...

• Indirect client services, such as: specification, repair or adaptation and training in the use of wheelchairs and other assistive devices for clients with temporary or permanent mobility impairments or declining functional capability...

• Meet with other health care providers, family, caregivers and others living and working with the client to facilitate rehabilitation, and to offer education and recommendations to facilitate the client's return to former roles and responsibilities.

This submission was accepted by the Council.

The majority of submissions received from respondents during the Council's consultation process addressed the risk to the public in the practice of occupational therapy when services are not performed by a qualified practitioner. It was the applicant's submission, under part 15 of the application for designation, that:

although most of the modalities used by occupational therapists are not inherently dangerous, a lack of knowledge about occupational performance and its supporting theories may cause a therapist to involve a client in routines or tasks that are not suited to the client's current skills and abilities. The result may be injury to the client, prolonged rehabilitation, or failure to return the client to a state of optimal occupational performance.

Some noteworthy examples provided of such risks include:

• aspiration pneumonia, in the management of feeding and swallowing disorders

• skin breakdown with risk of infection or increasing deformity, in specification of wheelchairs, splints or orthoses

• loss of mobility and increased pain, significantly affecting the person's ability to function in his or her home, workplace and in recreational pursuits.

In submissions to the Council, there was agreement that there is sufficient risk of harm in the practice of occupational therapy to justify designation in the public interest. In particular, the Muscular Dystrophy Association of Canada, the American Occupational Therapy Association, the British Columbia Association of Speech/Language Pathologists and Audiologists, the Canadian Association of Occupational Therapists, the Board of Registration for Social Workers, and the College of Physical Therapists of British Columbia all supported the designation of Occupational Therapy in the public interest, citing risk of harm. Support from these agencies for designation because of risk of harm was considered significant in the Council's conclusion.

It is the finding of the Council that there is sufficient risk of harm in the services provided by the profession to support designation in the public interest.

s. 5(1)(b) the technology, including instruments and materials, used by practitioners

Occupational therapists use an extensive array of technology to overcome or compensate for conditions that limit occupational performance. This includes provision of customized splints and orthotic devices, wheelchairs and seating devices and training in their use in activities of daily living.

While no submissions claimed an inherent risk of harm in the technology itself, statements were made that there is risk of harm in the application of such technologies if not applied by a qualified person.

s. 5(1)(c) the invasiveness of the procedure or mode of treatment used by practitioners

None of the services performed by occupational therapists are invasive.

s. 5(1)(d) the degree to which the health profession is

(i) practised under the supervision of another person who is qualified to practise as a member of a different health profession,

(ii) practised in a currently regulated environment

Almost 80 per cent of the members of the applicant society practice within a health care institution or other agency as part of a team of health care professionals with whom they consult and collaborate to provide multidisciplinary services. Others practise independently in homes, private offices or clinics, and the trend for this type of practice is increasing, according to the applicant. Therapists, including independent practitioners, communicate with the referral source as well as with the client's physician.

The Council also applied the facultative criteria in sections 5(2)(a) to (h) of the Regulations under the Act to the practice of Occupational Therapy.

s. 5(2)(a) the extent to which the health profession has demonstrated that there is a public interest in ensuring the availability of regulated services provided by the health profession

With respect to public interest in ensuring the availability of regulated services, the Council contacted the Arthritis Society, B.C. and Yukon Division; the B.C. Head Injury Association; the Canadian Mental Health Association, B.C. Division; the Multiple Sclerosis Society of Canada, B.C. Division; and the Muscular Dystrophy Association of Canada, B.C. and Yukon Region. There was very little public response, however the Muscular Dystrophy Association of Canada, B.C. and Yukon Division, submitted that:

There could be several advantages to the general public if occupational therapy were to become a self-governing profession under the Health Professions Act. A designated college could help clarify the occupational parameters, which are somewhat unclear at present. As well, it would be useful to have one identified place to call for questions, complaints and lists of qualified practitioners.

There was little other public interest expressed in the regulation of the profession of occupational therapy. This, however, was not of concern to the Council since occupational therapy services are well-established in the province.

s. 5(2)(b) the extent to which the services of the health profession provide a recognized and demonstrated benefit to the health, safety or well being of the public

The health benefits of occupational therapy were well documented in part 12 of the applicant's brief, supported in submissions from the American Occupational Therapy Association, the Canadian Association of Occupational Therapists, the College of Physical Therapists of B.C., the B.C. Association of Speech/Language Pathologists and Audiologists, the Board of Registration for Social Workers, the B.C. Association of Podiatrists, and the Muscular Dystrophy Association of Canada, and virtually unquestioned by any of the participants in the consultative process. See Public Interest Criteria, s.5(1)(a), on page 8 of this report for some examples of the services provided by occupational therapists.

s. 5(2)(c) the extent to which there exists a body of knowledge that forms the basis of the standards of practice of the health profession

The World Federation of Occupational Therapists sets out a defined body of knowledge and standards for educational programs leading to a degree or diploma in occupational therapy. The Canadian Association of Occupational Therapists (CAOT) also sets standards for such programs in Canada. Membership in the applicant society requires successful completion of the national certification examination offered by the CAOT.

s. 5(2)(d) whether members of the profession are awarded a certificate or degree from a recognized post-secondary educational institution

There are twelve CAOT-accredited programs at the baccalaureate level for occupational therapists in Canada. Baccalaureate degree programs for occupational therapists in Canada are available at the following universities:

The University of British Columbia
University of Alberta
The University of Manitoba
The University of Western Ontario
McMaster University
University of Toronto
Queen's University
University of Ottawa
Université de Montréal
McGill University
Université Laval
Dalhousie University

Educational programs in some countries are similar, e.g., bachelor degree programs in the U.S.A., Australia and some sites in the United Kingdom. Other countries offer diploma programs, e.g., the United Kingdom and New Zealand, which are substantially the same in professional content, but with fewer hours of basic arts and science courses.

Occupational therapists with diplomas from countries which meet the World Federation standards are eligible to write the national certification examination in Canada. If successful, they may apply for membership in the CAOT and provincial regulatory bodies which enable practice as an occupational therapist in Canada.

The majority of employers of occupational therapists in British Columbia require registration with the applicant society and/or CAOT-membership. The membership requirements of CAOT and the provision of a national certification examination and national standards for accreditation of academic programs and fieldwork sites facilitates mobility of occupational therapists throughout Canada. Although reciprocal agreements between provinces do not exist at this time, the occupational therapist meeting the criteria for one provincial regulatory body likely has the required documentation to obtain registration or a license to practice in other provinces. A summary of provincial regulation of occupational therapists is provided at Appendix B.

Currently, in British Columbia, anyone can practice occupational therapy so long as he or she does not use the title "Registered Occupational Therapist". This title is reserved under the Society Act to members of the applicant society. Only members of the applicant society are subject to its Code of Ethics.

s. 5(2)(e) whether it is important that continuing competence of the practitioner be monitored

In the Council's view, the monitoring of continuing competence is important in the practice of any health profession which involves a risk of harm.

The evolving technological advances in the rehabilitation field with regard to therapies and equipment make the monitoring of continual competence imperative.

s. 5(2)(f) the extent to which there exists within the health profession recognized leadership which has expressed a commitment to regulate the profession in the public interest

The fact that the applicant has represented the majority of practising occupational therapists since 1945 is indicative of leadership and cohesion. This view is further strengthened by the connections of the society with national and international organizations.

s. 5(2)(g) the likelihood that a college established under the Act would be capable of carrying out the duties imposed by the Act, having regard to factors which in the view of the council may affect the viable operation of the college

The leadership, cohesion, and substantial membership of the applicant society (868 occupational therapists, or 89% of an estimated 972 British Columbia occupational therapists) would indicate that a college established under the Act would be financially and administratively viable.

s. 5(2)(h) whether designation of the health profession is likely to limit the availability of services contrary to the public interest

No evidence was submitted that designation of the profession under the Act would limit the availability of services. Given that almost 90% of occupational therapists are currently qualified and members of the applicant society, it is the Council's conclusion that designation is unlikely to limit the availability of services.

In accordance with the prescribed Public Interest Criteria, the Council has concluded that: there is a significant risk of harm in the practice of occupational therapy; it would be in the public interest to designate occupational therapy as a self governing profession under the Act; and a college would be capable of carrying out the duties imposed by the Act.

B. NAME OF THE COLLEGE

The Council recommends the use of the practitioners' title, i.e., "occupational therapists", rather than the title of the profession, i.e., "occupational therapy", in naming the College.

C. RESERVED TITLE

The applicant had requested the use of either "Registered Occupational Therapist", which would continue the use of the titles currently protected under the Society Act for members registered with the applicant, or "Occupational Therapist".

The Council considers that a reserved title for occupational therapists is in the public interest and will assure the public and other health professionals that anyone using the title is a registrant of the College and is therefore qualified and is subject to disciplinary processes for incompetent, impaired, or unethical practice. A reserved title will enhance consumer recognition. The inclusion of the term "registered" was suggested but it is not consistent with the practice of the Council to use the term "registered" for members of self-regulating colleges designated under the HPA. It has been the Council's practice to reserve the descriptive term, such as "occupational therapist" for exclusive use of members of the college so that use of the term "registered" is unnecessary.

The Council further recommends that any other titles reserved under the Society Act which conflict with the above recommendation regarding reserved titles for occupational therapists should be reviewed by the Minister of Health as they may be misleading to the public. It is the Council's view that the current situation where other titles with respect to health professions can be reserved under s.9(1) of the Society Act is not in the public interest. Unlike the Council's review of an application for designation under the HPA, the Registrar under the Society Act does not conduct a detailed public interest analysis of the society, its membership or the services it provides with a view to regulation of the members of the applicant society. The Council believes that the title protection system under the Society Act could be confusing or misleading to members of public who may conclude on the basis of the exclusive use of title conferred under the Society Act , that a health professional is subject to regulation which does not, in fact, exist. In addition, there is no restriction on a health care worker using a title which includes the words registered, licensed or certified even though he or she has not been granted a title under either the Society Act or the HPA. In the Council's view, such unregulated use of these terms is not in the public interest as it may imply government sanction.

In its 1991 Report: The Royal Commission on Health Care and Costs recommended that:

7. a. the Society Act be amended so that the Health Professions Council must approve an occupational title or abbreviation before the Registrar grants protection of it;

b. all of the health profession titles previously granted protection under the Society Act that have not been approved by the Health Professions Council be revoked two years after the passing of the revised Health Professions Act; and

c. the Health Professions Act be amended to prohibit the use of words like "registered", "licensed" or "certified" by any health care worker unless that use has been approved by the Health Professions Council.

The Council adopts and supports these conclusions and recommends their implementation by the Minister of Health.

D. SCOPE OF PRACTICE

These services include, but are not limited to:

• assessment of occupational performance ability including the physical, cognitive, affective and environmental factors that may impede function,

• identification and prioritisation of occupational performance challenges and goals,

• prevention of conditions that will limit occupational performance,

• maintenance, development and restoration of occupational performance ability,

• specification, selection and training in the use of assistive devices and technology to overcome or compensate for conditions that limit occupational performance,

• analysis and adaption of occupations, activities or environments to promote independence and promote health in occupational performance,

• education of clients, families and caregivers related to effective occupational performance,

• consultation, referral, and collaboration with the client, family members and other professionals, and

• research.

The applicant initially proposed the following scope of practice:

Occupational therapists are health professionals with expertise in the assessment and remedy of occupational performance disorders. Occupational performance refers to the ability of a person to safely and effectively do the everyday activities necessary for self care, productivity and leisure. Self care includes eating, dressing, personal hygiene, mobility and functional communication. Productivity includes school readiness, work, homemaking, creative and expressive activities, and volunteer work. Leisure refers to play activities and pastimes of interest to the individual.

Occupational performance disorders may result from disease, injury, aging, social disadvantage or other impairments leading to physical, mental or emotional disabilities.

Professional services provided by occupational therapists promote engagement in occupational performance. Services are provided to clients of all ages. Services include:

• assessment of occupational performance ability and the physical, mental, sociocultural and spiritual components upon which occupational performance is predicated

• identification and priorization of occupational performance problems and goals

• prevention of occupational performance deficits

• maintenance, development and restoration of occupational performance ability

• assessment and remediation of physical, mental and emotional components/skills that are required for successful occupational performance

• prescription, selection and training in use of assistive devices and technology to overcome or compensate for occupational performance deficits

• analysis and adaptation of occupations, activities or environments to promote independence in occupational performance

• education of clients, families and caregivers related to effective occupational performance

• education of student occupational therapists, aides, technicians and other professionals

• consultation, referral and collaboration with other professionals

• research.

With regard to this initially proposed scope of practice, those respondents who took a position had a wide range of written responses. Manitoba Health stated that the proposed scope of practice was significantly broader than that of occupational therapists in Manitoba and in the 1983 position statement of the Canadian Occupational Therapy Association, "Occupational Therapy: Core Identity". Saskatchewan Health took the position that the proposed scope definition was too broad for a general definition in a statute and encompassed the activities of many other practitioners. The Ontario Ministry of Health commented that the proposed scope may be too specific and suggested the wording of the Ontario Occupational Therapy Act, 1991, which describes the scope of practice in broad definitions instead of lists of specific services, and which precludes the need for frequent legislative amendments. The B.C. College of Psychologists felt that the proposed scope needed clarification since it appeared to include activities for which occupational therapists were not trained, but which were within the scope of practice of psychologists. The B.C. College of Physicians and Surgeons had reservations about several specific services listed within the general scope of occupational therapy practice which overlap with activities regularly carried out by occupational medicine practitioners.

After meeting with the Council, and in response to the consultation process, the BCSOT submitted modifications to their scope of practice proposal. It is the revised scope of practice proposal upon which this report is based and which was the subject of the hearing.

At the hearing, respondents stated that the changes made to the scope of practice statement by the applicant had addressed their concerns. The Council was satisfied that the revised scope of practice statement sufficiently described what the profession of occupational therapy does, the methods it uses, and the purpose for which it does it. With some minor consolidation of phrases, the recommended scope of practice statement reflects the revised scope of practice statement submitted by the applicant.

E. RESERVED ACTS

The Council has now adopted the term "reserved act" rather than "exclusive scope of practice" for those tasks and services involving a significant risk of harm which can only be performed by those health professions authorized to perform them under their governing legislation.

The applicant requested the following reserved acts:

Proposed Exclusive Scope of Practice

Occupational therapists use activity analysis and adaptation in selecting activities or occupations to achieve defined therapeutic goals. This use of purposeful task engagement (a therapeutic strategy) is unique to occupational therapy. While it is difficult to claim exclusivity with regard to occupation or activity in relation to everyday living, it is the principal modality of occupational therapy and if not appropriately prescribed clients can be at risk for re-injury (sic) or unnecessarily prolonged rehabilitation in the process of learning or relearning everyday activities.

A number of services related to enhancing occupational performance should only be done by qualified occupational therapists. The decision to seek exclusive scope for this range of services is based on the potential risk involved to the client.

The following services are recommended for exclusive scope (with noted exceptions):

Service

identification and remediation of feeding and swallowing disorders

Exceptions:

Speech and Language Pathologists
Dieticians/Nutritionists
Physiotherapists
Nursing

Service

provision of customized splints and orthotic devices, and training in their use in activities of daily living

Exceptions:

Physiotherapists
Orthotists

Concerns about the proposed reserved acts were submitted by the Prosthetic and Orthotic Association of British Columbia, the British Columbia Association of Speech/Language Pathologists and Audiologists, the Registered Nurses Association of British Columbia, the College of Physical Therapists of British Columbia, the College of Physicians and Surgeons of British Columbia, and the British Columbia Board of Registration for Social Workers.

The main concern expressed by these groups was that some of these same services are also provided by physiotherapists, prosthetic and orthotic specialists, social workers, nurses, physiatrists, and speech and language pathologists. It is the Council's view that the proposed reserved acts are encompassed by the scope of practice of occupational therapists and should not be designated as reserved.

Submissions from other provinces questioned the need for reserved acts for occupational therapists and none are established in other jurisdictions. Responses received included the following:

Manitoba Health: It is our view that the list of services proposed to be reserved for occupational therapists is inappropriate and would not likely be included in legislation in this Province.

New Brunswick Health and Community Services: The Department today would question the desirability of restricting the practice of those tasks to one or two professions, given the changing health delivery system and the discussion which is occurring both nationally and provincially regarding shared competency and increased integration of training amongst disciplines. Finally I would refer you to the report, "Integrated Health Human Resources Development: A Framework for Discussion:, developed by four national associations representing Dieticians, Nurses, Occupational Therapists and Physiotherapists. The report identifies the elements of integrated health human resources development, and the inter-relationships and key factors which influence those elements. One of the key strategies identified under the heading "Key Result Areas and Examples of Strategies, Governance and Regulation" is the following: "Continue to test new models for flexible integrated approaches to professional regulation that recognize shared competencies and move away from exclusive scopes of practice." The proposal of the BCSOT appears to be inconsistent with the approach being recommended by the national association. (Emphasis added0

Ontario Ministry of Health: In Ontario, any person can . . . . perform a number of the acts and services which you propose to limit to OTs (subject to certain specific exceptions) including wheelchair prescription, sensorimotor evaluation, identification of feeding/swallowing disorders, and provision and training in the use of splints and orthotic devices.

Saskatchewan Health: Saskatchewan Health currently regulates occupational therapy under the Registered Occupational Therapists Act. While occupational therapy is defined, there are no general or specific restrictions on the scope of practice . . . . to ensure future flexibility in the use of occupational therapists as well as other health practitioners, I would suggest that no specific acts should be reserved for occupational therapists.

These views are consistent with the policy of the Council to recommend broad and, in some cases, overlapping scopes of practice and to eliminate narrow, restrictive, and exclusive scopes of practice, unless absolutely necessary to ensure public safety. The risk of harm from the proposed reserved acts was not shown to be especially hazardous, pervasive, or highly likely to occur, given that the services are provided by a qualified occupational therapist, whose qualifications to practice are substantiated by the College, as the regulatory body.

It was the Council's view that the proposed reserved acts are encompassed in the scope of practice of occupational therapists and need not be designated as reserved acts for the protection of the public. The establishment of a College of Occupational Therapists will regulate all aspects of the scope of practice of occupational therapists in the province. This will be sufficient regulation to protect the public from harm in the practice of occupational therapy. Although the scope of practice review has not been completed for the existing regulated health professions, if any restrictions in scope of practice should result in reserved acts which would affect the provision of services by occupational therapists, the Council will review this recommendation.

1. ASSOCIATIONS

American Occupational Therapy Association British Columbia Association of Speech/Language Pathologists & Audiologists
British Columbia Dietitians' and Nutritionists' Association

Canadian Association of Occupational Therapists
Canadian Association of Rehabilitation Personnel - British Columbia Society
Prosthetics and Orthotics Association of British Columbia

2. HEALTH PROFESSIONS

Association of Physiotherapists and Massage Practitioners
Board of Registration for Social Workers
British Columbia Association of Podiatrists
British Columbia Council of Licensed Practical Nurses
College of Dental Surgeons of British Columbia
College of Physicians and Surgeons of British Columbia
College of Psychologists of British Columbia
Registered Nurses' Association of British Columbia
Registered Psychiatric Nurses' Association of British Columbia

3. CONSUMER AND OTHER ORGANIZATIONS

Arthritis Society - BC and Yukon Division
British Columbia Head Injury Association
British Columbia Health Association
Canadian Mental Health Association - B.C. Division
Multiple Sclerosis Society of Canada - B.C. Division
Muscular Dystrophy Association of Canada - B.C. and Yukon Region

4. EDUCATIONAL PROGRAMS

The University of British Columbia, Division of Occupational Therapy, School of Rehabilitation Medicine

5. OTHER MINISTRIES

Ministry of Skills, Training and Labour

6. OTHER PROVINCES

Alberta Health
Alberta Professions and Occupations Bureau
Manitoba Health
Newfoundland and Labrador Department of Health
New Brunswick Health and Community Services
Northwest Territories Health and Social Services
Nova Scotia Department of Health
Ontario Ministry of Health
Prince Edward Island Department of Health and Social Services
Quebec Ministry of Health
Saskatchewan Health
Yukon Health and Social Services