There is a rise in the number of exclusive oral pathology practitioners in India. POPMA is an association that empowers & supports oral pathologists in India. (Image: Canva)
Dr. Bhuvan Nagpal, MDS is a practicing oral pathologist and the founder of the Practicing Oral Pathologists and Microbiologists Association (POPMA)— a professional body established to safeguard the interests of practicing oral pathologists in India.
About Dr. Bhuvan Nagpal:
Dr. Bhuvan Nagpal is currently serving as Laboratory Director, Quality Head, and Senior Consultant Oral Pathologist at Tohana Manglam Diagnostics, Tohana, Haryana. He is a Govt.-notified and NABL-approved authorized signatory for laboratory reports. He is also the Founder and current President of the Practicing Oral Pathologists and Microbiologists Association (POPMA). He is the Director of the Academy of Oral Pathology and Laboratory Medicine (AOPLM). Dr. Nagpal is also the Director of the Centre for Oral Pathology and Maxillofacial Diagnostics (C-OPMD). He has been affiliated with more than 23 Oral Pathology/General Pathology/Clinical Biochemistry/Oncology/Dental Professional Associations.
Dear Dr. Nagpal, please share with us your inspiring journey in the medical diagnostics industry.
Dr. Bhuvan Nagpal
I started my journey in the medical diagnostics industry immediately after completing my MDS. I first approached Manglam Diagnostics, a reputed diagnostic center with more than 30 years of experience in pathology/laboratory medicine, radiology, nuclear medicine, and blood bank services in Hisar City, Haryana. It is an NABL & NABH-accredited Diagnostic Centre. At Manglam Diagnostics, I was exposed to a variety of allied branches of laboratory medicine such as hematology, serology, clinical pathology, clinical biochemistry, cytopathology, histopathology, microbiology, immunoassay, and molecular pathology. I proved my worth with hard work and dedication.
Initially, I joined Manglam Diagnostics as a Consultant Oral Pathologist. Over time, I was promoted to Laboratory Administrator and Quality Manager. A few years later, I took on the role of Project in-charge for establishing new diagnostic centers at Jind, Tosham, Tohana, Fatehabad, Bhiwani, and Moonak. I then became the Chief Administrative Officer (CAO) and later a Medico-Legal Consultant. Currently, I am working as the Laboratory Director of my diagnostic center, Tohana Manglam Diagnostics. Tohana Manglam Diagnostics is an NABL-accredited laboratory with ISO number 15189-2012. I became the primary NABL-approved authorized signatory for laboratory reports. My name is also registered with the Clinical Establishment Act – District Registrar Authority (CEA-DRA) at Fatehabad. My scope of signatory includes Hematology, Clinical Biochemistry, Clinical Pathology, Infectious disease serology, and Microbiology along with Histopathology and Cytopathology of the Oral, Head, and Neck regions.
I also have a specialized Oral Pathology practice dedicated to diagnosing Oral Cancer & Maxillofacial Diseases, named the Centre for Oral Pathology & Maxillofacial Diagnostics (C–OPMD). I evaluate clinically and then conduct histopathological examinations of Oral Potentially Malignant Disorders, cystic lesions, swellings, benign and malignant tumors, cysts and tumors of odontogenic origin, and non-odontogenic lesions from the Head and Neck region, along with salivary gland disorders and tumors, and other orofacial anomalies.
Recently, I established a national-level association— Practicing Oral Pathologists and Microbiologists Association (POPMA). It is a professional body of practicing oral pathologists and microbiologists in India. It is registered under section 9(1) of the Haryana Registration and Regulation of Societies Act, 2012, with Registration number HR/12/2023/01797 dated 29th September 2023. The main concern of this association is to safeguard the interests of oral pathologists in India who want to practice this subject.
What is the scope of an Oral and Maxillofacial Pathologist in India?
According to the Dental Council of India (DCI) Revised M.D.S. Course Regulations, 2007 and 2017 published in The Gazette of India: Extraordinary (Part III, Section 4), an Oral Pathologist should have adequate training and competency to report the following laboratory tests: Histopathology & Cytopathology of specimens belonging to oral & perioral tissues, Routine Hematology, Clinical Pathology, Routine Microbiology, Routine Serology, Routine Clinical Biochemistry, Molecular Pathology and Ultrastructural Investigations.
The Gazette of India is a public journal and an authorized legal document of the Government of India, published weekly by the Department of Publication, a subordinate office of the Ministry of Housing and Urban Affairs. The Gazette is printed by the Government of India Press.
The specialty practice of the domain of Oral Pathology & Microbiology is not only limited to Oral, Head & Neck Histopathology and Cytopathology but also includes hematology, clinical pathology, clinical biochemistry, serology, microbiology, and even molecular pathology/diagnostics.
According to the Medical Council of India (MCI) and the National Medical Commission (NMC), Dentistry is one of the 29 recognized broad medical specialties and is also taught during the MBBS curriculum. According to the recent Judgment passed by the Honorable Madras High Court on 23.03.2023 which states that BDS is also a recognized modern system of medicine dealing with dentistry. Oral Pathology & Microbiology is an overlapping branch of dentistry as well as pathology and in turn, signifies an integral part of modern scientific medicine.
Can you tell us about your legal journey to achieve a signatory status for MDS oral pathologists?
I filed my first RTI in 2015 during the second year of my postgraduation, concerning the scope of oral pathology. From 2016 onwards, I have filed numerous RTIs to the MCI, DCI, and prominent government and private dental colleges with the Oral Pathology and Microbiology Department. I have written many emails regarding the authorized signatory status of MDS oral pathologists to the Ministry of Health & Family Welfare (MOHFW), Government of India. I have also advocated for making MDS Oral Pathology and Microbiology one of the requisite qualifications for authorized signatories for lab reports to the National Accreditation Board for Testing and Calibration Laboratories (NABL) and to the suggestions working committee for the Clinical Establishments Act, Government of India.
As per the replies to RTIs filed to various dental colleges, qualified Oral Pathologists holding MDS degrees in the subject of Oral Pathology & Microbiology have been signing lab reports for many years. These reports cover routine hematological, cytological, microbiological, biochemical, immunological, and histopathological investigations referred to the Dept. of Oral Pathology & Microbiology in government and private dental colleges recognized by the DCI. Another RTI reply from the Dental Council of India confirmed that a dentist can perform procedures included in the syllabus/course curriculum of MDS Oral Pathology & Microbiology.
What are the documental proofs that empower Oral Pathologists to sign clinical laboratory/pathology reports with the specified investigations?
According to the current Bhartiya Sakshya Adhiniyam (BSA), 2023, and Indian Evidence Act, 1872 (which is repealed), the term “document” means “any matter expressed or described or otherwise recorded upon any substance by means of letters, figures or marks or any other means or by more than one of those means, intended to be used, or which may be used, for the purpose of recording that matter and includes electronic and digital records”. Primary Evidence is the best available proof of the existence of an object or a fact because it is an actual document or the authentic source of evidence. Secondary evidence is the evidence that has been duplicated from a unique report or has been substituted from the first thing. Public Documents are those documents that are authenticated by a public officer and subsequently which is made available to the public at large for reference and use. They include Central Acts, orders, or notifications which are certified by the Heads of the departments concerned, and Proceedings of the Legislatures – Journals of those bodies or copies printed by the Govt. Information obtained under the RTI Act is part of the documents held by Public Authority, who are Gazetted officers. A certified copy of a document received by virtue of the RTI Act is secondary evidence. It can be used as Secondary Evidence in Court, since it is part of the Government records and provided by Govt. Authorities, certified under Govt. Seal.
Primary Evidence Under Section 57 Of Bhartiya Sakshya Adhiniyam, 2023 (which corresponds to Section 62 Of Indian Evidence Act, 1872)
• Dental Council of India (DCI) MDS Regulations, 2007 & 2017 for the subject of Oral & Maxillofacial Pathology and Oral Microbiology
• Dental Council of India (DCI) B.D.S. Internship Regulations, 2011
• Dental Council of India (DCI) Dentist Code of Ethics, 2014
• NABL approval letter to DCI regarding MDS Oral Pathology & Microbiology qualification as one of the authorized signatories for lab reports, 2018
Secondary Evidence Under Section 58 Of Bhartiya Sakshya Adhiniyam, 2023, And Section 63 Of Indian Evidence Act, 1872
• Replies to RTI filed to prestigious government dental institutions from different parts of India by Dr Bhuvan Nagpal from the year 2016 to 2019
• Minutes of the meeting of MOHFW regarding the Medical Diagnostic Laboratories including signing authority/Technical head of medical diagnostic laboratory held in the years 2017 & 2018
• RTI reply stating that a dentist can perform the procedures whatever is present in the syllabus/course curriculum of MDS Oral Pathology & Microbiology, 2020
• NABL Decision Letter for grant of accreditation to Tohana Manglam Diagnostics, 2022 & 2024 in which Dr. Bhuvan Nagpal is the NABL-approved signatory for lab reports with hematology, clinical pathology, clinical biochemistry, infectious disease serology, and microbiology as the scope of accreditation.
What is the vision and mission of the Practicing Oral and Maxillofacial Pathologist Association (POPMA)?
We have laid down a strong foundation for the Practicing Oral and Maxillofacial Pathologists Association (POPMA), where our vision is to unite and empower oral pathologists in India.
The mission of POPMA includes:
• To promote the specialty practice of Oral and Maxillofacial Pathology & Oral Microbiology.
• To encourage Oral Pathology & Microbiology as a career by making an MDS Oral Pathology & Microbiology degree as one of the requisite qualifications to sign the laboratory reports/authorized signatory for lab reports.
• To elevate the scientific and professional status of those practicing this specialty of dentistry/medicine/pathology.
• To advocate the highest standards in education, research, and the practice of Oral Pathology and Microbiology.
• To represent and magnify the value of oral pathology & microbiology to other medical and dental organizations, legislative bodies, and government agencies.
• To encourage closer cooperation of oral and maxillofacial pathologists with clinicians of different specialties and with other medical/dental/pathology/biochemistry/microbiology organizations.
What would be the take-home message from this interview?
Overlapping scope of practice is a reality in a rapidly changing healthcare environment. Several health sciences and medical technology professionals play a key role in diagnosis, treatment, and patient care. No single healthcare professional can claim an exclusive role in diagnosis and treatment. The criteria related to who is qualified to perform functions safely without risk of harm to the public are the only justifiable conditions for defining the scope of practices as per the suggested parameters. Competency is someone’s subjective dedication & ability, and not based on qualifications alone. It is rightly said “survival of the fittest,” so competent people will survive. Oral Pathologists are qualified healthcare and laboratory professionals who are authorized to sign laboratory reports and they can play a major and important role in medical diagnostic laboratory.
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