Royal College of Dental Surgeons of Ontario v. Dr. Richard Gordon Bunt, 2025 ONRCDSO 6

DISCIPLINE COMMITTEE OF THE ROYAL COLLEGE OF DENTAL SURGEONS OF ONTARIO

Date: 2025-08-18

File No.: 25-0028

IN THE MATTER OF: A Hearing held pursuant to the provisions of the Health Professions Procedural Code which is Schedule 2 to the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 (“Code”)

AND IN THE MATTER OF: the Dentistry Act and Ontario Regulation 853, Regulations of Ontario, 1993, as amended (“Dentistry Act Regulation”)

AND IN THE MATTER OF: the Statutory Powers Procedure Act, Revised Statutes of Ontario, 1990, Chapter S.22, as amended; 1993, Chapter 27; 1994, Chapter 27

BETWEEN:

Royal College of Dental Surgeons of Ontario

-and-

Dr. Richard Gordon Bunt

FINDING AND PENALTY REASONS

RESTRICTION ON PUBLICATION

In the matter of the Royal College of Dental Surgeons of Ontario and Dr. Bunt the Discipline Panel ordered, under ss 45(3) of the Health Professions Procedural Code, that no person shall publish or broadcast the identity of any patients of the Registrant, or any information that could disclose the identity of any patients who are named in the Notice of Hearing and/or the Agreed Statement of Facts in this matter.

PANEL MEMBERS:

Judy Welikovitch, Public Member (Chair)

Dr. Daniel Fortino, Professional Member

Luisa Ritacca, Subject Matter Expert

APPEARANCES:

Anastasia Hountalas, for the College

John McIntyre, for Dr. Bunt

Heard: August 18, 2025, by video conference

Decision Date: August 18, 2025

Release of Written Reasons: November 3, 2025

REASONS FOR DECISION

1This matter came on before a panel of the Discipline Committee (the “Panel”) of the Royal College of Dental Surgeons of Ontario (the “RCDSO”) on August 18, 2025. This matter was heard by way of videoconference.

2At the commencement of the hearing, the College sought a publication ban prohibiting any person from publishing or broadcasting the identity of any patient of the Registrant, or any information that could disclose the identity of a patient named in the Exhibits marked at the hearing or in the submissions made orally at the hearing. The Registrant consented to the College’s request. The Panel granted the order.

3The Panel notes that the College entered the following documents as exhibits prior to making its submissions:

(a) Notice of Hearing No. 25-0028 (the “NOH”), as Exhibit 1;

(b) Written plea enquiry signed by the Registrant on August 9, 2025, as Exhibit 2; and

(c) Agreed Statement of Facts (the “ASF”), signed by the parties, as Exhibit 3.

THE ALLEGATIONS

4This matter concerns Dr. Bunt’s alleged misconduct in relation to dental services provided to ten (10) minor-aged patients, all of whom were under the age of twelve (12) years, including three (3) who were under three (3) years of age.

5The allegations of professional misconduct against the Registrant, Dr. Richard Bunt, are set forth in the Notice of Hearing. A copy of the redacted Notice of Hearing is appended to these Reasons, as Appendix “A”.

6The Notice of Hearing contains three (3) separate allegations of professional misconduct, as follows:

Allegation 1: Treated a disease, disorder or dysfunction that he knew/ought to have known, was beyond his expertise or competence

7The College alleged that Dr. Bunt committed professional misconduct as provided by Section 51(1)(c) of the Health Professions Procedural Code (the “ Code”), being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 (the “Act”) in that during 2022, Dr. Bunt treated or attempted to treat a disease, disorder or dysfunction of the oral-facial complex that he knew or ought to have known was beyond his expertise or competence relative to ten (10) patients, contrary to Section 2(5) of Ontario Regulation 853/93, Regulations of Ontario. 1993, as amended (the “Regulation”).

8More particularly, the College alleged that in or about 2022, Dr. Bunt administered sedation to three (3) patients, all of whom were under three (3) years of age, without having completed the required post-graduate training in paediatric dentistry, anaesthesiology or oral maxillofacial surgery suitable for certification in Ontario and without the required authorization.

9The College further alleged that in or about 2022, Dr. Bunt administered an oral sedative that exceeded the maximum dose permitted for one appointment for patients under twelve years of age without having completed the necessary specialty training in pediatric dentistry, anesthesiology or oral and maxillofacial surgery. This allegation concerned ten (10) children, all of whom were under the age of twelve (12). Three (3) of these patients were under the age of three (3), as mentioned above.

Allegation 2: Contravened Standards of Practice

10It is agreed by the parties that in the first three months of 2022, Dr. Bunt did have an authorization to administer minimal sedation. It is further agreed, however, that on March 31, 2022, Dr. Bunt’s authorization to administer minimal sedation expired and he did not seek to renew that authorization. Further, it is agreed by the parties that Dr. Bunt’s authorization to administer minimal sedation was cancelled effective April 11, 2022, because it was not renewed (ASF, Paragraphs 3 and 4).

11The College alleged that Dr. Bunt committed acts of professional misconduct as provided by Section 51(1)(c) of the Code in that, during 2022, he induced general anaesthesia to ten (10) patients, all of whom were under the age of twelve (12), including three (3) of whom were under the age of three (3) years, contrary to Section 2(11) of the Regulation.

12The particulars regarding Allegation 2 include the particulars alleged in Allegation 1.

13In addition, the College alleged that Dr. Bunt administered oral moderate sedation and/or nitrous oxide and oxygen sedation to nine (9) of the ten (10) minor-aged patients, including the three (3) minor-aged patients who were under three (3) years of age. It was alleged that he did so without having obtained the necessary training (as described under Allegation (1)) and without having obtained the necessary facility permit to provide oral moderate sedation.

14The College alleged that, in 2022, in relation to nine (9) of the ten (10) patients described above, Dr. Bunt administered an oral sedative that exceeded the maximum dose permitted for one appointment for patients under twelve (12) years of age without having completed the necessary specialty training. Of these patients, three (3) were under the age of three (3) years.

15Further, the College alleged that in 2022, Dr. Bunt continued to administer sedation to all ten (10) of the minor-aged patients concerned, after the cancellation by the College of his minimal sedation authorization on April 11, 2022.

16The College further alleged that Dr. Bunt’s record-keeping was entirely inadequate; that there was no documentation of a pre-operative functional inquiry or ASA classification; that there was no documentation of pre-operative, intra-operative or post-operative vital signs; that there was inadequate documentation that patient discharge criteria were met; and that Dr. Bunt discharged one of his young patients prematurely and without a proper assessment.

Allegation 3: Disgraceful, Dishonourable, Unprofessional or Unethical Conduct (‘DDUU”)

17Lastly, the College alleged that Dr. Bunt committed professional misconduct as provided by Section 51(1)(c) of the Code in that, during 2022 and/or 2023, he engaged in conduct or performed an act or acts that, having regard to all the circumstances, would reasonably be regarded by registrants of the College as disgraceful, dishonourable, unprofessional or unethical, contrary to Section 2(59) of the Regulation. The allegation included that in or about 2022, he was guilty of unethical conduct in that he failed to prioritize the health and well-being of his patients.

The Registrant’s Plea

18Dr. Bunt admitted the allegations of professional misconduct contained in the Notice of Hearing. A written plea inquiry, signed by Dr. Bunt on August 9, 2025, was accepted by the Panel and was entered as Exhibit 2. The Chair also conducted an oral plea enquiry. Based upon the Registrant’s plea and his responses to questions posed by the Chair, the Panel was satisfied that Dr. Bunt’s admissions were voluntary, informed, and unequivocal.

The Evidence: Exhibit 3 including admissions by Dr. Bunt

19On consent of the Registrant, the College introduced into evidence an Agreed Statement of Facts and Admission of Professional Misconduct (“ASF”) (Exhibit 3).

20The evidence before the Panel included a copy of the Interim Order of the Inquiries, Complaints and Reports Committee (the “ICRC”), which was signed on January 15, 2025, and prohibits Dr. Bunt from administering “any form of sedation”. The interim order was attached to the ASF (Exhibit 3) at Tab A.

21The ASF contains admissions of professional misconduct by Dr. Bunt, including:

(a) That he held a minimal sedation authorization that was issued on April 1, 2020 and expired on March 31, 2022;

(b) That his minimal sedation authorization was cancelled effective April 11, 2022 because it was not renewed;

(c) That registrants must hold at least an oral moderate authorization to administer any oral sedation to patients under the age of twelve (12) years;

(d) That Dr. Bunt agreed and admitted that at no time was he authorized to administer sedation to paediatric patients under twelve (12) years of age because he lacked both the necessary training and authorization to do so;

(e) That more specifically, Dr. Bunt agreed and admitted that, during the course of treating the ten (10) minor-aged patients referred to above:

i. He repeatedly administered moderate sedation, oral sedation and nitrous oxide and oxygen to his patients while holding a minimal sedation authorization;

ii. He administered sedation in an amount that exceeded the maximum dose permitted for one appointment on approximately six (6) occasions;

iii. He administered sedation to three (3) patients who were under the age of three (3) years on approximately five (5) occasions while holding only a minimal sedation authorization and without having completed a formal post-graduate program in paediatric dentistry;

iv. He continued to administer oral sedation to his ten (10) minor-aged patients on approximately forty-three (43) occasions after having received the College’s cancellation notice of his minimal sedation permit;

v. He failed to document that he instructed the ten (10) minor-aged patients or their caregivers to adhere to the necessary pre-sedation fasting requirements;

vi. He failed to monitor patient vital signs as required pre-operatively, intra-operatively and post-operatively;

vii. He discharged one (1) of his minor-aged patients prematurely and without a proper assessment;

(f) That Dr. Bunt agreed and admitted that in treating the ten (10) patients referred to above for frenectomies, that he treated or attempted to treat a disease, disorder or dysfunction that he knew or ought to have known was beyond his expertise or competence;

(g) That Dr. Bunt agreed and admitted that the conduct described above in sub-paragraphs (a) – (f) was unethical in that he failed to prioritize his patients’ health and well-being and he thereby put his patients at risk of harm or injury;

(h) That Dr. Bunt agreed and admitted that his record-keeping was sub-standard, as described in paragraph 16 above.

22Dr. Bunt agreed and admitted that the evidence as described above constitutes professional misconduct pursuant to Section 51(1)(c) of the Code and Sections 2(5) and (11), and Section 2(59) (disgraceful, dishonourable, unprofessional or unethical conduct) of the Regulation.

Decision

23The Panel considered the evidence set forth in the ASF and the submissions of the parties. We find, on a balance of probabilities, that there is sufficient evidence to establish that the Registrant committed the acts of professional misconduct as alleged in the Notice of Hearing (Exhibit 1).

Reasons for Decision

24The Notice of Hearing sets out three allegations against the Registrant. Broadly speaking, the grounds of professional misconduct are (a) unauthorized and/or improper sedation of minor patients, (b) inadequate record-keeping, and (c) disgraceful, dishonourable, unprofessional or unethical conduct.

25In his written plea enquiry (Exhibit 2), and in the ASF (Exhibit 3), Dr. Bunt agreed with and admitted that he was guilty of professional misconduct, as alleged.

1: Improper/Unauthorized Sedation of Minor Patients: The Evidence

26The evidence before the Panel establishes, on a balance of probabilities, that the parents and/or caregivers of ten (10) children, all of whom were under twelve (12) years of age, and including three (3) of whom were less than three (3) years old, entrusted Dr. Bunt with the oral health care of their children. They each placed their respective trust in Dr. Bunt.

27Dr. Bunt admitted that, in 2022, he treated these children for frenectomies, a procedure that required that they undergo sedation. He further admitted that performing frenectomies was beyond his level of skill and expertise.

28Dr. Bunt further admitted that he held only a minimal sedation authorization which, in any event, expired on March 31, 2022 and which was formally cancelled by the College on April 11, 2022.

29Dr. Bunt further admitted that he continued to administer oral sedation to ten (10) minor patients on approximately forty-three (43) occasions following the cancellation of his minimal sedation authorization and despite having admittedly received the College’s cancellation notice.

30The College’s “Standard of Practice: Use of Sedation and General Anesthesia in Dental Practice” (the “SOP” or the “Standard”) (Exhibit 3, Tab C) states that:

“(a) Registrants with minimal sedation authorization cannot administer oral minimal sedation to patients under the age of twelve (12), regardless of whether minimal sedation is intended or achieved;

(b) Registrants must hold at least oral moderate authorization to administer any oral sedation to patients under the age of twelve (12); and

[c] only registrants who are qualified to administer deep sedation or general anesthesia and have completed a formal post-graduate program in pediatric dentistry may administer oral sedation to patients under the age of three (3).” (emphasis added)

31These standards were acknowledged and admitted by Dr. Bunt.

32Dr. Bunt admitted that he administered sedation to three (3) young patients, all of whom were under the age of three (3) years, on approximately five (5) occasions. While he was, prior to March 31, 2022, authorized to administer minimal sedation, this was insufficient to allow him to administer any sedation at all to a child under the age of twelve (12) years, and particularly to patients under three (3) years of age.

33Dr. Bunt admitted that, when performing frenectomies, he administered oral sedation to ten (10) minor-aged patients without proper authorization and that he thus treated or attempted to treat a disease/disorder/dysfunction of the oral-facial complex that he knew or ought to have known was beyond his competence or expertise, and in disregard of the prohibition against doing so set out in the Sedation SOP.

34Further, Dr. Bunt admitted that he repeatedly administered oral moderate sedation and nitrous oxide and oxygen sedation to ten (10) minor-aged patients, in disregard of the Sedation SOP. He also admitted to administering oral moderate sedation in an amount that exceeded the maximum dose permitted for one appointment on approximately six (6) occasions. He admitted that he did so without having completed the necessary specialty training in pediatric dentistry, anesthesiology or oral and maxillofacial surgery, and all in disregard of the prohibition against doing so set out in the Sedation SOP.

35Lastly, Dr. Bunt admitted that the agreed facts set out in the ASF constitute professional misconduct pursuant to section 51(1)(c) of the Code and as set out in Section 2(59) of the Regulation. In other words, Dr. Bunt agreed and admitted that the course of his professional misconduct, as described above, falls within the full scope of the language of section 2(59) of the Regulation.

Findings

36The allegations before this Panel are serious and the Panel takes them seriously. Dr. Bunt’s actions put young children at risk of harm. Dr. Bunt admitted that he failed to prioritize the health and well-being of his young, paediatric patients. His admissions of professional misconduct have been accepted by this Panel with the seriousness they deserve.

37Further, the Panel considered the allegations and Dr. Bunt’s admissions in light of the Sedation SOP which highlights the special attention that dentists must pay to their more vulnerable patients, including children, the elderly, and medically compromised people who face particular challenges when receiving sedation or general anaesthesia.

38With respect to children, the Sedation SOP states the following:

“…Children under 12 years of age – especially under 3 years of age – require even more diligent monitoring; they have reduced physical reserves and impairment may occur rapidly. In particular, it can be difficult to diagnose hyperventilation and airway obstruction quickly.” [1] (emphasis added)

39The Panel finds that Dr. Bunt did not adhere to the diligence required of him when treating his young, more vulnerable patients.

40The Panel finds the Registrant’s admissions and acknowledgements in the ASF to be true, credible and reliable evidence of his professional misconduct.

41More specifically, the Panel finds that Dr. Bunt held a minimal sedation authorization until March 31, 2022, when it expired, and further, that the certificate was cancelled by the College on April 11, 2022.

42The Panel also finds that pursuant to the Sedation SOP, Dr. Bunt was not authorized to administer even minimal sedation to patients under the age of twelve (12) years at all, notwithstanding that he was authorized to administer minimal sedation to older patients.

43Further, the Panel finds that Dr. Bunt was not authorized to administer sedation to patients under the age of three (3) years at all, with even more stringent requirements for authorization in place than for children in the four (4)-to- twelve (12) year age group.

44More particularly, the Sedation SOP sets a high standard for treating such young patients. In order to administer any sedation to a child under the age of three (3) years, two conditions must be met: (a) the dentist must be authorized to administer deep sedation or general anaesthesia; and (b) the dentist must have completed a formal post-graduate program in paediatric dentistry. The Panel finds that Dr. Bunt did not meet either condition.

45The Panel thus finds, on a balance of probabilities, that Dr. Bunt is guilty of professional misconduct as provided by Section 51(1)(c) of the Code in that, during 2022;

a) he treated or attempted to treat a disease, disorder or dysfunction of the oral-facial complex that he knew or ought to have known was beyond his expertise or competence, contrary to Section 2(5) of the Regulation. This included that

i. he administered oral moderate sedation on multiple occasions to ten minor-aged patients, all of whom were under the aged of twelve (12) years;

ii. in this regard, he administered sedation to three (3) patients who were under the age of three (3) years without authorization and without having completed the required post-graduate training in paediatric dentistry; and

iii. he administered oral moderate sedation to ten minor-aged patients; and

b) he contravened the standard of practice for sedation as set out in the Sedation SOP relative to the ten (10) minor-aged patients referred to above on multiple occasions, contrary to Section 2(11) of the Regulation.

2: Inadequate Record-keeping

46One of the hallmark standards of practice for dentists relates to recordkeeping. The Dental Recordkeeping Guideline² (the “Guideline”), approved by Council in November 2019, states the following:

“Dentists have professional, legal and ethical responsibilities to maintain a complete record of each patient’s dental care. Clear, accurate and up-to-date patient records are essential to the delivery of high quality care.

Patient records must be well-organized, legible, understandable and readily accessible. They remind the dentist of past and present conditions of the patient and treatments already provided, and they facilitate communication with other practitioners involved in the patient’s care. For effective continuity of care, another dentist should be able to review the record easily and carry on with the patient’s treatment.”³

47The Guideline establishes basic record-keeping requirements.

Findings

48The evidence before the Panel as set out in the ASF establishes that in or about 2022, Dr. Bunt’s record-keeping was entirely inadequate with respect to the ten (10) minor-aged patients under his care who are the subjects of this hearing.

49In this regard, Dr. Bunt admitted that, in or about 2022, with respect to the ten (10) minor-aged patients referred to above, he:

a) Failed to document a pre-operative functional inquiry or ASA classification;

b) Failed to document pre-operative, intra-operative or post-operative vital signs; and

c) Inadequately documented that patient discharge criteria were met.

50The Panel finds the Registrant’s admissions and acknowledgements in the ASF to be true, credible and reliable evidence of his professional misconduct.

51The Panel thus finds, on a balance of probabilities, that Dr. Bunt is guilty of professional misconduct as provided by Section 51(1)(c) of the Code in that, during 2022, he contravened the Guideline, contrary to Section 2(11) of the Regulation.

3: Disgraceful, Dishonourable, Unprofessional or Unethical Conduct:

52The third ground of professional misconduct contained in the NOH relates to conduct that would reasonably be regarded by registrants of the profession as disgraceful, dishonourable, unprofessional or unethical, contrary to Section 2(59) of the Regulation.

53The first of the particulars set out under this ground alleged that Dr. Bunt’s conduct was “unethical in that (he) failed to prioritize the health and well-being of (his) patients.” This allegation contains no reference to the other grounds of unprofessional conduct enumerated in Section 2(59) of the Code.

54In this regard, Dr. Bunt admitted, at paragraph 10 of the ASF, that his conduct as described at paragraph 2 – 9 of the ASF, was “unethical” because he “failed to prioritize the health and well-being of his pediatric patients and put the patients at risk of harm or injury.”

55The Panel finds that the conduct described at paragraphs 2 – 9 of the ASF was egregious and that it would reasonably be regarded by other registrants of the profession as unethical, at a minimum.

56Further, at sub-paragraph 13(iii) of the ASF, Dr. Bunt admitted to professional misconduct pursuant to Section 51(1)(c) of the Code, contrary to Section 2(59) of the Regulation, without limitation. He admitted that the agreed facts as set out in the ASF constitute professional misconduct, as follows:

“iii. Paragraph 59: Engaging in conduct or performing an act that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable, unprofessional or unethical.”⁴ [emphasis added]

57The Panel notes that during submissions, counsel for Dr. Bunt stated that the Registrant was admitting to unethical conduct only, although he agreed that Dr. Bunt’s conduct was, by implication, “unprofessional” as well.

Findings

58While the Panel took note of counsel’s submissions, it considers the Registrant’s admission contained at sub-paragraph 13(iii) of the ASF, and in the oral and written plea enquiries, to be credible and reliable evidence that, in an overall sense, he engaged in conduct that would reasonably be regarded by registrants of the profession as disgraceful, dishonourable, unprofessional or unethical (DDUU). The Panel finds that this admission applies to all of the professional misconduct admitted and agreed to by Dr. Bunt.

59The Panel is cognizant that the DDUU ground of professional misconduct is written in the alternative. The word “or” is disjunctive. Within the context of this case, this means that Dr. Bunt admitted that the full course of his professional misconduct was disgraceful or dishonourable or unprofessional or unethical.

60The Panel finds that Dr. Bunt’s professional misconduct was serious and that it put young children at risk of harm.

61Further, the Panel finds that, in treating the children entrusted to his care, Dr. Bunt acted in disregard of their health and safety. He acted in disregard of the risk of harm posed to his very vulnerable patients. His professional misconduct involved multiple children; it involved multiple occurrences that took place over the course of a number of months in 2022. In the Panel’s view, Dr. Bunt’s conduct is not limited to being unprofessional and unethical. The Panel finds that registrants of the profession would reasonably find that Dr. Bunt’s conduct was also disgraceful and dishonourable.

Conclusion

62To summarize, the Panel finds, on a balance of probabilities, that Dr. Bunt engaged in serious professional misconduct in relation to ten (10) patients, all of whom were under the age of twelve (12) years, including three (3) of whom were under the age of three (3) years.

63The Panel finds Dr. Bunt’s admitted disregard for the health and well-being of children who were entrusted to his care to constitute professional misconduct of a most serious nature. He treated ten (10) children under the age of twelve (12), using varying levels of sedation.

64In so doing, he also acted in disregard of the Sedation SOP. This Standard emphasizes that children under the age of twelve (12) years, and especially those under the age of three (3) years, are vulnerable; that the standards and requirements for dentists to be able to administer sedation to these young children are more stringent than they are for patients of the age of majority; that the children require special care and monitoring.

65Specifically, Dr. Bunt admitted, and the Panel finds that, on a balance of probabilities, he engaged in serious professional misconduct as contemplated by Section 51(1)(c) of the Code. The Panel finds that Dr. Bunt failed to prioritize the health and well-being of his minor-aged patients; that his disregard for their safety and well-being put them at risk of harm. This included that:

a) He treated or attempted to treat a disease, disorder or dysfunction of the oral-facial complex that he knew or ought to have known was beyond his expertise or competence, contrary to Section 2(5) of the Regulation. This included that he administered sedation to three (3) patients who were under the age of three (3) years without having completed the required post-graduate training in paediatric dentistry;

b) He contravened the Sedation SOP in relation to inducing sedation or general anaesthesia or conscious sedation relative to the ten (10) minor-aged patients referred to above, three (3) of whom were under the age of three (3) years, contrary to Section 2(11) of the Regulation.

c) He contravened the Dental Recordkeeping Guideline, contrary to Section 2(11) of the Regulation (ASF, para. 11);

d) He engaged in conduct that was unethical in that he failed to prioritize the health and well-being of his paediatric patients and thus put those patients at risk of harm or injury; (ASF, paras. 2 - 10); and

e) He also engaged in conduct that would reasonably be regarded by registrants of the profession as disgraceful, dishonourable, and unprofessional, contrary to Section 2(59) of the Regulation (ASF, para.13(iii)).

Joint Submission on Penalty and Costs (Exhibit 4)

66Following the conclusion of the hearing on the merits, and the Panel’s delivery of its Decision, the hearing moved into the penalty phase. The parties presented the Panel with a Joint Submission on Penalty and Costs (“JSPC”) (Exhibit 4). The JSPC was signed by Dr. Bunt on August 8, 2025, and by counsel for the College on August 13, 2025.

67Pursuant to the Panel’s finding that Dr. Bunt is guilty of professional misconduct as described above, the Parties asked the Panel to make an Order on the following terms:

a) requiring Dr. Bunt to appear before the Panel to be reprimanded immediately following the hearing of this matter;

b) Directing the Registrar to suspend Dr. Bunt’s certificate of registration (the “Certificate”) for a period of three (3) months, commencing on the date of the Panel’s Order;

c) Directing the Registrar to impose the terms, conditions and limitations on Dr. Bunt’s certificate of registration (“Suspension Conditions”) which shall continue until the suspension of the certificate of registration has been fully served. These terms, conditions and limitations include that:

i. While the Registrant’s Certificate is under suspension, the Registrant shall immediately inform the people listed in subparagraph 1(c)(1) of the JSPC about the suspension;

ii. While suspended, the Registrant shall not engage in the practice of dentistry including in all manners delineated in subparagraph 1(c)(1)(ii) of the JSPC;

iii. While suspended, the Registrant must not be present in offices or practices where the Registrant works, when patients are present, except for emergencies that do not involve patients. The Registrant must immediately advise the Registrar in writing about any such emergencies (subparagraph 1(c)(1)(iii));

iv. While suspended, the Registrant must not benefit or profit, directly or indirectly from the practice of dentistry, according to the terms and conditions set out in subparagraph 1(c)(1)(iv) of the JSPC;

v. The Registrant shall cooperate with any office monitoring which the Registrar feels is needed to ensure that the Registrant has complied with the Suspension Conditions. To that end, the Registrant must provide the College with access to any records associated with the practice that the College may require to verify that the Registrant has not engaged in the practice of dentistry or profited during the suspension from the practice of dentistry during the suspension period (subparagraph 1(c)(1)(v) of the JSPC); and

vi. The Suspension Conditions described above shall be removed from the Certificate at the end of the suspension period (subparagraph 1(c)(1)(vi) of the JSPC

d) Directing the Registrar to also impose terms, conditions and limitations on the Certificate, all to be completed at his own expense, as follows:

i. Successful completion of a dental recordkeeping course, pre-approved by the College, prior to his return to practice, and provide proof of successful completion in writing to the College upon completion of the course;

ii. Monitoring of his practice by means of office visits by a representative(s) (the “practice monitors”) of the College during the period commencing with the date of the finalization of the Discipline Committee’s order and ending twenty-four (24) months from the College receiving proof of the Registrant’s successful completion of the course on recordkeeping, or until the Inquiries, Complaints and Reports Committee (the “ICRC”) is satisfied that the Registrant has successfully completed the monitoring program, whichever is later. The monitor’s office visits shall be held at such time(s) as the College may determine, with advance notice to the Registrant;

iii. The Registrant shall cooperate with the College during the office visit(s) described above and, further, shall pay to the college in respect of the costs of monitoring, the amount of one thousand dollars ($1000.00) per visit immediately after the completion of each office visit; and

iv. The practice monitor(s) shall report the results of the office visit(s) described above to the ICRC of the College and the ICRC may, if deemed warranted, take such action as it considers appropriate; and

e) Requiring that Dr. Bunt pay costs to the College in the amount of ten thousand dollars ($10,000.00) within thirty (30) days of the date of the Discipline Committee’s Order; and lastly,

f) Requiring the Registrar to ensure that the results of these proceedings be recorded on the register of the College and any publication of the Panel’s decision would therefore include with the name and practice address of the Registrant.

Undertaking Signed by Dr. Bunt (Exhibit 5)

68Significantly, and in addition to the JSPC, the Parties also tendered an Undertaking signed by Dr. Bunt on August 8, 2025, in which he agreed that he:

a) Will not administer minimal, moderate or deep sedation, nor will he administer minimal general anesthesia as defined in the College’s Standard of Practice: Use of Sedation and General Anesthesia in any dental facility or otherwise in his practice in Ontario; and

b) Will not apply to the College for any authorization to administer minimal sedation, oral moderate sedation, parenteral conscious sedation, deep sedation or general anesthesia.

69In this regard, it is important that, at paragraph 4 of the Undertaking, Dr. Bunt acknowledged that he was entering into the undertaking in exchange for the College not requesting that the Discipline Committee impose a term, condition or limitation on his Certificate requiring him to successfully complete a College-approved course in sedation and anesthesia.

70Further, at paragraph 10 of the Undertaking, Dr. Bunt declared that he understood that if he breached the Undertaking, including but not limited to, by administering minimal, moderate or deep sedation, or general anesthesia, or by applying to the College for sedation authorization after the date of the Undertaking, being August 8. 2025, that the College will, in its sole discretion, have the right to prosecute him for a breach of the Undertaking and to rely on the signed Undertaking for that purpose.

71As noted, a copy of the Undertaking was entered as Exhibit 5. For greater clarity, the Panel notes that the title of the document entered as Exhibit 5 is “Undertaking”, although it is referred to within as an “Acknowledgement and Undertaking”

72College counsel highlighted the contents of the Registrant’s Undertaking in which Dr. Bunt acknowledged that the “Acknowledgement and Undertaking is a binding agreement between (himself) and the College and is in full force and effect immediately upon signing…” (Undertaking, Paragraph 7).

73College counsel made submissions in support of the terms and conditions of the JSPC. Her submissions spoke to the penalties agreed upon by the parties, their rationale, and the objectives that they would achieve. She argued that the fact that the complaints concerned pediatric patients and that they concerned forty-three (43) incidents over a period of months in 2022 were aggravating factors. Conversely, the fact that this was Dr. Bunt’s first appearance before a panel of the Discipline Committee, that he admitted his misconduct at the very beginning of this matter, and that the College received a high level of cooperation from him throughout the proceedings, were all submitted to be mitigating factors.

74College counsel further submitted that the reprimand that the Panel was being asked to administer would have both specific and general deterrent effects; that the requirements that Dr. Bunt take a course in record-keeping, pre-approved by the Registrar, and that he undergo practice monitoring for twenty-four (24) months would ensure the Registrant’s remediation; that these penalties would thereby serve to protect the public and to reinforce public confidence in the ability of the profession to regulate itself.

75College counsel further submitted that the imposition of a 3-month suspension would provide both specific and general deterrence, it would reinforce public confidence in the College’s ability to regulate the dental profession, and that it would strengthen protection of the public. Counsel also stressed that the Undertaking signed by the Registrant, in which he undertook not to administer minimal, moderate or deep sedation or to apply for an authorization to do so, offers the public a significant degree of protection.

76In providing the Panel with a reference point for an appropriate overall penalty, College Counsel referred the Panel to a number of cases in which similar issues were decided. Of note:

a) RCDSO v Kirschner (20 February 2020; H190002), in which it was alleged that Dr. Kirschner committed professional misconduct when he administered anesthesia to a single patient, and where Dr. Kirschner had already taken a one-day, one-on-one course in anesthesia, the Registrant received a one-month suspension, was required to complete courses in record keeping and informed consent, and was further required to undergo practice monitoring; and

b) RCDSO v Motruk, (RCDSO Dispatch, Summaries of Recent Discipline Committee Hearings, Decision One; May/June 2009), in which it was alleged that Dr. Motruk committed professional misconduct when he prescribed and administered anesthesia to a three-year-old child, with adverse consequences, the Registrant received a reprimand, a three-month (3-month) suspension, was required to complete a course in anesthesiology and in ethics, was restricted from treating minor-aged patients with any conscious sedation until successful completion of the course in anesthesiology, and was further required to undergo practice monitoring for twenty-four (24) months.

77In her submissions, College Counsel stressed that, absent the Undertaking signed by Dr. Bunt, that the College would likely have sought a different penalty; that the College is satisfied with the penalty proposed by the parties in large part because of the Undertaking, underscoring that this document is significant in that it protects the public from potential future harm.

78Counsel for the Registrant adopted the submissions of College Counsel. He focussed his submissions on the mitigating factors present in this case. He stressed that Dr. Bunt realizes that his conduct posed a risk of harm to his patients but countered that no harm came to any of them. He noted that, in his view, the penalty being proposed was greater than the penalties ordered in five (5) of the six (6) cases relied upon by the College, although he acknowledged that it was within a comparable range.

Penalty Decision

79The Panel accepts the joint submission of the parties and makes an Order (the “Order”) in accordance with the terms set forth in the JSPC, as follows:

1. THAT the Registrant is required to appear before the panel of the Discipline Committee to be reprimanded immediately following the hearing of this matter;

2. THAT the Registrar suspend the Registrant’s certificate of registration for a period of three (3) months, commencing on the date of this Order. The suspension shall run without interruption.

3. THAT the Registrar impose the following terms, conditions and limitations on the Registrant’s certificate of registration (the “Suspension Conditions”), which Suspension Conditions shall continue until the suspension of the Registrant’s certificate of registration as referred to in paragraph 5 above has been fully served:

a. while the Registrant’s certificate of registration is under suspension, the Registrant shall immediately inform the following people about the suspension:

i. staff in the offices or practices in which the Registrant works, including other regulated professionals and administrative staff;

ii. dentists with whom the Registrant works, whether the Registrant is a principal in the practice or otherwise associated with the practice;

iii. dentists or other individuals who routinely refer patients to the Registrant;

iv. faculty members at Faculties of Dentistry, if the Registrant is affiliated with the Faculty in an academic or professional capacity;

v. owners of a practice or office in which the Registrant works;

vi. patients who ask to book an appointment during the suspension, or whose previously booked appointment has been rescheduled due to the suspension. The Registrant may assign administrative staff to inform patients about the suspension. All communications with patients must be truthful and honest;

b. while suspended, the Registrant must not engage in the practice of dentistry, including but not limited to:

i. acting in any manner that suggests the Registrant is entitled to practice dentistry. This includes communicating diagnoses or offering clinical advice in social settings. The Registrant must ensure that administrative or office staff do not suggest to patients in any way that the Registrant is entitled to engage in the practice of dentistry;

ii. giving orders or standing orders to dental hygienists;

iii. supervising work performed by others;

iv. working in the capacity of a dental assistant or performing laboratory work;

v. acting as a clinical instructor;

c. while suspended, the Registrant must not be present in offices or practices where the Registrant works when patients are present, except for emergencies that do not involve patients. The Registrant must immediately advise the Registrar in writing about any such emergencies;

d. while suspended, the Registrant must not benefit or profit, directly or indirectly from the practice of dentistry and

i. the Registrant may arrange for another dentist to take over their practice during the suspension period. If another dentist assumes the practice, all of the billings of the practice during the suspension period belong to that dentist. The Registrant may be reimbursed for actual out-of-pocket expenses incurred in respect of the practice during the suspension period;

ii. the Registrant is permitted to sign and/or submit insurance claims for work that was completed prior to the suspension;

iii. the Registrant must not sign insurance claims for work that has been completed by others during the suspension period;

e. the Registrant shall cooperate with any office monitoring which the Registrar thinks is needed to ensure that the Registrant has complied with the Suspension Conditions. The Registrant must provide the College with access to any records associated with the practice that the College may require to verify that the Registrant has not engaged in the practice of dentistry or profited during the suspension; and

f. the Suspension Conditions imposed by virtue of subparagraphs 6(a)-(e) above shall be removed at the end of the period that the Registrant’s certificate of registration is suspended.

4. THAT the Registrar also impose the following additional terms, conditions and limitations on the Registrant’s Certificate of Registration, all to be completed at his own expense:

a. the Registrant shall successfully complete a dental recordkeeping course, pre-approved by the College, prior to his return to practice, and provide proof of successful completion in writing to the College upon completion of such course;

b. the Registrant’s practice in Ontario shall be monitored by the College by means of office visit(s) by a representative or representatives of the College at such time or times as the College may determine with advance notice to the Registrant, for twenty-four (24) months from the date after the day that the suspension is lifted or until the Inquiries, Complaints and Reports Committee is satisfied that the Registrant has successfully completed the monitoring program, whichever date is later;

c. the Registrant shall cooperate with the College during the office visit(s) described in paragraph 7(b) and further, shall pay to the College in respect of the costs of monitoring, the amount of $1,000.00 per office visit immediately after completion of each of the office visit(s);

d. that the representative or representatives of the College shall report the results of the office visit(s) described in paragraph 7(b) to the Inquiries, Complaints and Reports Committee of the College and the Inquiries, Complaints and Reports Committee may, if deemed warranted, take such action as it considers appropriate.

5. The panel orders that the Registrant pay costs to the College in the amount of $10,000.00 within 30 days of the date of this Order.

80Further, and pursuant to the Code, the College’s publication of this matter will include the Registrant’s name and address.

Reasons for Penalty Decision

81It is settled law that a decision-maker should not lightly depart from an agreement that has been reached by the parties with respect to an appropriate penalty. The test is not one of “fitness of sentence” but, rather, the more stringent test of “whether the jointly proposed penalty would bring the administration of justice into disrepute or would otherwise be contrary to the public interest.”⁵

82The Panel considered the terms of the JSPC in the context of the basic principles relating to the imposition of penalties. These well-settled principles include that:

(a) the goal of a penalty is to protect the public from dentists who have committed professional misconduct and to maintain public confidence in the profession and in its ability to self-regulate;

(b) the penalty must serve as a measure of general deterrence in that it sends a message to all registrants of the dental profession that this type of conduct will not and cannot be tolerated;

(c) the penalty serves as a measure of specific deterrence with respect to the dentist concerned;

(d) it provides for rehabilitation or remediation of the dentist concerned, where possible and appropriate, to ensure that the dentist practices at a standard acceptable to the profession and to protect the public; and lastly,

(e) both mitigating and aggravating factors should be considered.

83For the reasons that follow, the Panel accepted the parties’ joint position with respect to penalties and costs and concluded that the proposed penalties and the costs award to the College are reasonable and appropriate in the circumstances of this case.

84Dr. Bunt was first licensed to practise dentistry in Ontario approximately twenty-seven (27) years ago, in July 1998. This was his first appearance before a panel of the Discipline Committee. The matter which led to this hearing was dealt with by the ICRC in File No. 23-0033 and that was the first time Dr. Bunt had a matter before that body [ASF, Tabs A and B]

85In her oral submissions, College Counsel relied upon the JSPC but noted that the Undertaking [Exhibit 5] signed by Dr. Bunt “completes the picture”, and the Panel agrees. She expressed the view that no remediation in sedation was required for Dr. Bunt because of the terms of his Undertaking.

Mitigating Factors

86The Panel finds that there are mitigating factors that support its acceptance of the joint submission. These include that (a) Dr. Bunt has been practising dentistry for approximately twenty-seven (27) years with a heretofore unblemished record; (b) Dr. Bunt acknowledged his misconduct right away; and (c) he demonstrated a high level of cooperation with the investigation.

Aggravating Factors

87The Panel also finds that there are some serious and concerning aggravating factors at issue in this case. These include:

(a) that Dr. Bunt held a minimal sedation authorization only and that expired on March 31, 2022, and was cancelled by the College on April 11, 2022;

(b) that on April 13, 2022, the College sent notice of the cancellation of his minimal sedation permit to Dr. Bunt at his email address registered with the College. The College’s records indicated that the email was received by Dr. Bunt (ASF, Para. 4. Cancellation notice attached as Tab B to ASF);

(c) Dr. Bunt’s admission that at no time was he authorized to administer sedation to pediatric patients under twelve (12) years of age at all because he lacked both the necessary training and the authorization to do so (ASF, Para 6);

(d) Dr. Bunt’s admission that he nevertheless administered moderate sedation, oral sedation and nitrous oxide and oxygen to ten (10) patients who were less than twelve (12) years of age, including three (3) patients who were less than three (3) years old (ASF, paras. 8(a), (b)). In other words, notwithstanding that he did have an authorization to administer minimal sedation, Dr. Bunt admitted that this authorization was insufficient to allow him to administer sedation to his minor-aged patients;

(e) Dr. Bunt admitted that the administration by him of more than minimal sedation to ten (10) minor-aged patients, three (3) of whom were less than three (3) years of age, were not isolated incidents but occurred over a period of months on multiple occasions in 2022 (ASF paras. 8(a), (b) and (c));

(f) Significantly, Dr. Bunt administered more than minimal sedation to these ten (10) patients on a total of forty-three (43) separate occasions after his minimal sedation permit had been cancelled by the College on April 11, 2022 and after the College notified him by email of the cancellation on April 13. 2022 , when he was, therefore, not permitted by the College to administer any sedation at all (ASF para. 8(c) ); and

(g) Dr. Bunt admitted that in treating these young patients by performing frenectomies, he had been practising beyond the level of his competence or expertise (ASF, para.9).

88The Panel also finds that the professional misconduct admitted by Dr. Bunt included (a) a failure to appropriately document his actions adequately, (b) that he failed to monitor patient vital signs pre-, intra-, and post-operatively, as he was required to do, and (c) that he discharged one (1) of his minor-aged patients prematurely and without a proper assessment (ASF, paras. 8(e),(f)).

89Lastly, Dr. Bunt admitted, and the Panel finds, that he failed to prioritize his patients’ health and well-being and that he thereby put his very young patients at serious risk of harm or injury.

90These findings are serious and have been taken very seriously by this Panel.

Reprimand Ordered

91In view of these findings, the Panel ordered that Dr. Bunt appear before it to be reprimanded. Dr. Bunt waived his right to an appeal and asked that the reprimand be read at the conclusion of the hearing. The Panel did so. The reprimand is appended to these Reasons as Appendix “B”.

92The reprimand delivered at the conclusion of the hearing will have the following impact:

(a) It will have a general deterrent effect in that it is a public denunciation by the Panel of Dr. Bunt’s conduct. This will send a clear message to members of the profession that this type of professional misconduct cannot and will not be tolerated;

(b) It will achieve the goals of transparency and public accountability, and it will strengthen public confidence in the profession’s ability to regulate itself and to hold dentists accountable for poor conduct or practice; and

(c) It will have a specific deterrent effect upon Dr. Bunt himself.

93At the conclusion of the reading of the reprimand, Dr. Bunt was offered an opportunity to make a comment, and he availed himself of that opportunity. He expressed that he was “deeply remorseful” about his conduct, that he was grateful that no harm had come to any of his young patients, and that he respected the decision of the Panel.

94In making these statements, the Panel finds that Dr. Bunt showed remorse and demonstrated a level of insight into his misconduct upon which this Panel hopes that Dr. Bunt can build and move forward.

Three-Month Suspension

95In view of the seriousness of Dr. Bunt’s professional misconduct, the Panel ordered that Dr. Bunt must serve a three (3)-month suspension from practice upon the terms and conditions outlined in the JSPC and the Suspension Conditions, and in the Order issued by this Panel.

96A suspension will serve the goals of specific and general deterrence. It will also serve to strengthen public confidence in the ability of the dental profession to self-regulate. The imposition of a three (3) – month penalty will also assure the public that public safety is a top priority for the Discipline Committee.

97The Panel finds that a suspension of three-months’ duration is consistent with the range gained from the cases referred to above and further cases contained in the College’s Book of Authorities. In making this finding, the Panel notes that the proposed three-month duration of suspension was acceptable to it largely in light of the Undertaking signed by Dr. Bunt.

Practice Monitoring and Approved Course in Record Keeping Ordered

98The Panel ordered that, prior to resuming his practice after the suspension period, Dr. Bunt shall have completed a College-approved course in record-keeping.

99The Panel also ordered that Dr. Bunt will be monitored by the College by means of office visits by a representative of the College for a period of twenty-four (24) months from the date that the suspension is lifted or until the ICRC is satisfied that the Registrant has successfully completed the monitoring program, whichever date is later.

100Both the practice monitoring and requirement to successfully complete a record keeping course will provide Dr. Bunt with opportunities for remediation. They will also serve to ensure that Dr. Bunt’s level of practice meets College standards and they will provide a necessary element of protection for the public.

Costs Ordered

101Lastly, the Panel ordered that the Registrant pay costs to the College in the amount of $10,000 (ten thousand) dollars within thirty (30) days of the date of the Order signed on August 18, 2025. This payment will serve to reimburse the College for some of its costs related to the investigation and prosecution of this matter.

102In conclusion, the significant penalties imposed by this Panel reflect and communicate the seriousness with which we regard Dr. Bunt’s professional misconduct, especially in light of the threat of harm that his professional misconduct posed to ten (10) very vulnerable patients, all of whom were minors. The Panel is satisfied that the combined terms of the penalty order and the Undertaking signed by Dr. Bunt will ensure that public confidence in the profession is maintained, and that the public is protected.

I, Judy Welikovitch, sign these Reasons for Decision as Chairperson of this Discipline Panel.

APPENDIX “A”

25-0028

IN THE MATTER OF a Hearing of a panel of the Discipline Committee of the Royal College of Dental Surgeons of Ontario held pursuant to the provisions of the Health Professions Procedural Code which is Schedule 2 to the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 (“Code”) respecting one DR. RICHARD GORDON BUNT, of the City of Trenton, in the Province of Ontario;

AND IN THE MATTER OF the Dentistry Act and Ontario Regulation 853, Regulations of Ontario, 1993, as amended (“Dentistry Act Regulation”).

AND IN THE MATTER OF the Statutory Powers Procedure Act, Revised Statutes of Ontario, 1990, Chapter S.22, as amended; 1993.

TO: Dr. Richard Gordon Bunt

14 Whites Road, RR#2

Trenton ON K8V 5P5

NOTICE OF HEARING

TAKE NOTICE THAT IT IS ALLEGED THAT:

1. You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the year 2022, you treated or attempted to treat a disease, disorder or dysfunction of the oral-facial complex that you knew or ought to have known was beyond your expertise or competence relative to the following patients, namely LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, contrary to paragraph 5 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.

Particulars:

• In or about 2022, you administered sedation to your patients, LB, OR, and/or EV, who were under 3 years of age without having completed the required post-graduate training in paediatric dentistry, anesthesiology or oral and maxillofacial surgery suitable for certification in the Province of Ontario.

• In or about 2022, you administered an oral sedative that exceeded the maximum dose permitted for one appointment for patients under 12 years of age, namely, LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, without having completed the necessary speciality training in pediatric dentistry anaesthesiology or oral and maxillofacial surgery.

2. You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the year 2022, you contravened the standards of practice, as published by the College, in relation to inducing general anaesthesia or conscious sedation relative to the following patients, namely LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, contrary to paragraph 11 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.

Particulars:

• In or about 2022, you administered oral moderate sedation, oral sedation and/or nitrous oxide and oxygen sedation to your minor patients, LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, without the necessary authorizations.

• In or about 2022, you continued to administer sedation to your minor patients, LB, AB, AC, CC, VL, CL, OR, AT, BV and/or EV, after the cancellation of your minimal sedation authorization on April 11, 2022.

• In or about 2022, you administered sedation to your patients, LB, OR, and/or EV, who were under 3 years of age without having completed the required post-graduate training in paediatric dentistry, anesthesiology or oral and maxillofacial surgery suitable for certification in the Province of Ontario.

• In or about 2022, you administered an oral sedative that exceeded the maximum dose permitted for one appointment for patients under 12 years of age, namely, LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, without having completed the necessary speciality training in pediatric dentistry anaesthesiology or oral and maxillofacial surgery.

• In or about 2022, you failed to obtain the necessary facility permit to provide oral moderate sedation.

• In or about 2022, you failed to instruct your patients, LB, AB, AC, CC, VL, CL, OR, AT, BV, and/or EV, and/or their caregivers to adhere to the necessary pre-sedation fasting requirements.

• In or about 2022, your sedation recordkeeping was entirely inadequate:

o There was no documentation of a pre-operative functional inquiry or ASA classification;

o There was no documentation of pre-operative, intra-operative or post-operative vital signs;

o There was inadequate documentation that patient discharge criteria were met.

• In or about 2022, you failed to monitor your patients’ vital signs as required (pre-operatively, intra-operatively and post-operatively).

• In or about 2022, you discharged your patient, CC, pre-maturely and without a proper assessment.

3. You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the year 2022 and/or 2023, you engaged in conduct or performed an act or acts that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable, unprofessional or unethical, contrary to paragraph 59 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.

Particulars:

• In or about 2022, your conduct was unethical in that you failed to prioritize the health and well-being of your patients.

• On April 11, 2022, your minimal sedation authorization was cancelled, yet you continued to provide sedation services to your pediatric patients. These sedation services exceeded the level of service allowed by the previous authorization putting patients at risk of harm or injury.

• In or about April 12, 2022 to January 20, 2023, you ignored College correspondence cancelling your minimal sedation authorization by continuing to provide sedation services to your pediatric patients.

Such further and other particulars will be provided from time to time, as they become known.

AND TAKE NOTICE THAT the said allegations respecting professional misconduct will be heard and determined by a panel of the Discipline Committee of the Royal College of Dental Surgeons of Ontario ("panel") on a date and time to be agreed upon by the parties, or on a date to be fixed by the Chair of the Discipline Committee, at the offices of the Royal College of Dental Surgeons of Ontario, 6 Crescent Road, Toronto, Ontario, M4W 1T1, or by electronic hearing as required. You are required to appear in person or by a legal representative before the panel with your witnesses, if any, at the time and place aforesaid.

ONCE A DATE IS FIXED, IF YOU DO NOT ATTEND ON THE FIXED HEARING DATE, THE PANEL MAY PROCEED IN YOUR ABSENCE AND YOU WILL NOT BE ENTITLED TO ANY FURTHER NOTICE OF THE PROCEEDINGS.

The Code provides that if a panel finds that you have committed an act of professional misconduct, it may make an order doing any one or more of the following:

(1) directing the Registrar to revoke your certificate of registration;

(2) directing the Registrar to suspend your certificate of registration for a specified period of time;

(3) directing the Registrar to impose specified terms, conditions and limitations on your certificate of registration for a specified or indefinite period of time;

(4) requiring you to appear before the panel to be reprimanded;

(5) requiring you to pay a fine of not more than $35,000.00 to the Minister of Finance;

or any combination thereof.

Furthermore, the Code provides that if a panel is of the opinion that the commencement of these proceedings is unwarranted, it may make an order requiring the College to pay all or part of your legal costs.

The Code also provides that in an appropriate case, a panel may make an order requiring you, in the event the panel finds you have committed an act or acts of professional misconduct or finds you to be incompetent, to pay all or part of the following costs and expenses:

1. the College's legal costs and expenses;

2. the College's costs and expenses incurred in investigating the matter; and

3. the College's costs and expenses incurred in conducting the hearing.

If you have not done so already, you are entitled to and are well advised to retain legal representation to assist you in this matter.

You are entitled to disclosure of the evidence in this matter in accordance with section 42(1) of the Code. You or your representative may contact the prosecutor for the College, Anastasia Hountalas, in this matter at:

Anastasia Hountalas

Steinecke Maciura LeBlanc

401 Bay Street, Suite 2308, P.O. Box 23

Toronto ON M5H2Y4

Tel: 416.599.2200

email: ahountalas@sml-law.com

You, or your legal representative, should familiarize yourself with your disclosure obligations under law, including section 42.1 of the Code.

DATED at Toronto, this 5th day of February, 2025.

Royal College of Dental Surgeons of Ontario

IN THE MATTER OF a Hearing of a panel of the Discipline Committee of the Royal College of Dental Surgeons of Ontario held pursuant to the provisions of the Health Professions Procedural Code which is Schedule 2 to the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 (“Code”) respecting one DR. RICHARD GORDON BUNT, of the City of Trenton, in the Province of Ontario;

AND IN THE MATTER OF the Dentistry Act and Ontario Regulation 853, Regulations of Ontario, 1993, as amended (“Dentistry Act Regulation”).

AND IN THE MATTER OF the Statutory Powers Procedure Act, Revised Statutes of Ontario, 1990, Chapter S.22, as amended.

NOTICE OF HEARING

ROYAL COLLEGE OF DENTAL SURGEONS

OF ONTARIO

6 Crescent Road

Toronto ON M4W 1T1

Telephone: 416-961-6555

Fax: 416-961-5814

APPENDIX “B”

RCDSO v. Dr. Richard Gordon Bunt

Dr. Bunt, as you know, this Discipline panel has ordered you be given an oral reprimand as part of the sanction imposed upon you. The reprimand should impress upon you the seriousness of your misconduct.

The fact that you have received this reprimand will be part of the public portion of the Register and, as such, part of your record with the College.

You will be given an opportunity to make a statement at the end of the reprimand if you wish.

The panel has found that you have engaged in multiple acts of professional misconduct. The misconduct related to your improper use of sedation with respect to 10 minor patients, all of whom were under 12, with three under 3-years old. In all instances you did not have proper authorization and in addition, in one instance, you provided sedation in excess of what is set out in the College’s Standard. Your conduct did place young children at serious risk of harm. It is fortunate that no such harm occurred.

Further, the panel acknowledges that you did admit that your conduct would reasonably be regarded as unprofessional and unethical. The panel is of the view that members of this profession would find in addition that your conduct was disgraceful and dishonourable.

Your professional misconduct is a matter of profound concern. You put your patients at serious risk and your conduct undermines the public’s confidence in the profession.

The panel acknowledges your decision to sign an undertaking with the College not to administer any type of sedation or general anaesthesia. The panel believes that this undertaking will protect the public and minimize any future risk. Absent this undertaking, this panel is of the view that your misconduct could have attracted a more significant penalty.

Further, should you be found to have breached your undertaking at any point in the future, you should expect that a panel of the Discipline Committee will likely impose a more serious penalty than has been ordered here.

As I advised earlier, you will now be given an opportunity to make a comment if you wish to do so. This is not an opportunity for you to debate the merits or the correctness of the decisions we have made.

Do you have any questions or do you wish to make any comments?

(Hear the Registrant’s comments at this point)

Thank you for attending today. We are adjourned.

1ASF, Tab C, page 13

Footnotes

1. 2RCDSO Dental Recordkeeping Guideline, November 2019, Dental Recordkeeping Guidelines
2. 3Ibid, at p.2
3. 4ASF, page 3, paragraph 13(iii)
4. 5R v Anthony Cook, 2016 SCC 43, applied in the professional discipline context in Ontario College of Teachers v Merolle, 2023 ONSC 3453 at para 32