The writer of a recent letter, ‘Time for ADONZ to take over ODOB’s role’ (August 2025) expresses confusion over the ODOB’s (the Board’s) and the New Zealand Association of Optometrists’ (NZAO’s) perceived failure to address concerns about optical/optometry businesses operating without properly trained or registered staff. The letter writer further accuses the Board of being “unable or unwilling” to act in the interests of its members. However, this critique may reflect some uncertainty on the letter writer’s part about the regulatory process and the Board’s role within it.

The Board is established under the Health Practitioners Competence Assurance Act 2003 with the clear mandate of protecting the public by regulating optometrists and dispensing opticians. The Board’s jurisdiction is confined to registered practitioners. The issue raised in the letter concerning unregistered businesses or individuals falls outside the Board’s legislative remit and is, in fact, the responsibility of the Ministry of Health.

Nonetheless, the Board understand practitioners’ dissatisfaction where it seems there has been no action taken in relation to businesses appearing to have unregistered/untrained staff. Where such issues have been brought to the Board’s attention, the Board has notified the Ministry of Health. Given that the Board’s resources, primarily derived from fees charged to applicants and registrants, are not infinite, the Board must be mindful to focus on matters within its jurisdiction. Diverting resources to address issues outside this remit would be an inappropriate misallocation of funds and would impede the Board’s ability to discharge its legislative responsibilities.

The letter writer goes on to suggest that the Association of Dispensing Opticians of New Zealand (ADONZ) should take over responsibility for the regulation of dispensing opticians. While ADONZ and similar membership organisations are invaluable in their advocacy for their members and in support of professional development, they are not equipped, nor should they be, to regulate the professions for which they advocate. Regulatory oversight must be independent, impartial and transparent, conditions that cannot be guaranteed if a membership organisation, which represents the interests of its members, were to take on a regulatory role.

The idea of ADONZ assuming regulatory responsibilities introduces a clear conflict of interest and risks undermining the integrity of the regulatory process. Regulation must remain independent from professional advocacy to ensure that the public’s safety is the sole priority.

In summary, while the letter writer’s concerns about businesses operating without proper oversight are valid, their understanding of the regulatory process is flawed. The current system is designed to ensure public protection through an independent regulatory framework, and the Board must act within its legal jurisdiction. The proposals put forward by the letter writer fail to take account of the complexities of this framework and, if implemented, would ultimately weaken the system’s integrity.

Letters to the editor are welcome via email to info@nzoptics.co.nz. Please include your name, title and daytime telephone number. Letters may be edited, abridged or discarded due to content, space availability and clarity.