Correspondence: Robert Booth re: request for change in the definition of 'medical clinic'

View Royal Committee of the Whole

Thank you for taking the time to consider this letter. I am writing to make a request for a change in the definition of "medical clinic" in the View Royal bylaws with regards to home occupation.

I have been communication with the View Royal Planner, Mr. James Davison for the past few months regarding the requirements to setting up a home based Massage Therapy/Acupuncture practice. Mr. Davison has been extremely helpful in assisting my navigation of the bylaws for home occupation. I am aware that Victoria, Saanich, and I am sure most other municipalities allow home based Massage Therapy and Acupuncture practices. Mr. Davison has indicated that the primary barrier to my application would be that Massage Therapy/Acupuncture falls under the definition of a medical clinic. I would like to request that this be reconsidered as it is not defined as such by any other organization that I am aware of. Although Massage Therapists and Acupuncturists are primary health providers, we do not diagnose, treat or otherwise practice medicine, as I am sure any physician will attest to.

Both proffessions are regulated and under the Health Professions Act, and both are overseen by independant regulatory colleges; the College of Traditional Chinese Medicine & Acupuncturists (CTCMA), and the College of Massage Therapists of B.C. (CMTBC). I am a member in good standing with both colleges.

To practice Massage Therapy or Acupuncture a candidate must complete an approved and regulated program, then pass rigorous written and practical exams. After successful completion of these exams registrants are granted a licence which requires that regular continuing education be undertaken and that proof of appropriate insurance be submitted anually. Mr. Davison has indicated some concern about potential biohazard, and I would like to assure you all that none exists. In the practice of acupuncture, thin, fine needles (.22 mm diameter) are inserted into the skin. These needles are sterile, single use, and disposable. The needles are inserted through a plastic guide tube, to eliminate the possibility of infection, and when removed are disposed of in a sharps container. These sealed containers are approved for biomedical waste and are disposed of at the pharmacy. These are the same procedures diabetics use at home for disposal of insulin needles however I typically only use one 1000cc container per year. Because of the extremely small diameter of the needles there is rarely any bleeding, if there is it is typically a single drop on a cotton ball that is also disposed of in the same way.

The level of exposure to blood in a aesthetics business would be far greater than in an acupuncture practice, and I understand they are allowed under current home occupation bylaws.

I appreciate change comes slowly and that community members and neighbors want to preserve the spirit of their neighborhoods. I have already outlined to Mr. Davison I plan to organize my business as to make minimal impact on my neighbors, many of whom are eagerly awaiting my services! I would typically see only 3-5 clients per day 4 or 5 days per week. Appointments are typically one hour with 30 minutes in between to avoid congestion. This I believe would fit best as a level 2 home occupation.

I would like to thank you for your consideration in this matter, I would be happy to answer any questions or address any concerns this committee has regarding this request.

Sincerely,

Robert Booth, RMT, RAc.