I agree with the previous posted comments regarding the proposed narrowing of the permissible duties of veterinary personnel.  I am a veterinarian in a practice that promotes excellent dental exams and therapy, since it is so important to the overall health of our pet patients.  This change to regulations may actually prove detrimental to consumers and their pets.  I will explain my reasoning after a brief summary of the current procedures  (for  non-veterinarians).  Under anesthesia a thorough exam of the mouth is conducted,  tooth or gum problems are charted and a plan of action for therapy is prepared.  My dental assistant then removes the largest deposits of tartar with a hand tool prior to ultrasonically scaling the visible surfaces of the teeth.  This process may take 20-30 minutes during which time I am able to perform any other procedures needed for the pet.  After scaling is complete I will review the mouth tooth by tooth and address any problems that exist (need for dental X-rays, caries, mobile teeth, deep gum pockets, fractured teeth, tartar under the gum line).  After therapy is complete, my assistant  polishes the teeth, then rinses, dries and seals the tooth surfaces.      

      Except for the anesthesia, this sounds like going to the human dentist!  Minimizing the time under anesthesia dictates that we be very efficient.  If a veterinarian is required to perform all aspects of the dental procedure, then he will need to charge for his time rather than an assistant.   The time under anesthesia will typically be longer as any additional procedures planned for the animal will need be done sequentially not coincidentally.  The increased costs for the veterinarian's time and the prolonged anesthesia will mean many owners will be unable to afford it. Their pets will suffer.  (Note that I have neatly side-stepped the issue of the lack of veterinary technicians to fill this role, but even there, the cost factor is present.)

     Training and supervision of veterinary assistants in proper use of hand and ultrasonic methods is straightforward and is the responsibility of the veterinarian.  Major points for instruction include: use a light touch with the tip of the ultrasonic scaler (the sound waves gently vibrate away the attached tartar); don't stay on the same tooth for more than 10-15 seconds at a time as this can build up some heat ; leave any suspicious teeth, gum problems,  or tartar under the gum line for the veterinarian to tackle.  Changing these regulations would increase the costs and  anesthesia times (the riskiest part of the procedure) and would ultimately result in decreased level of care for many animals.  "Above all else, do no harm"  is our veterinarian's creed---follow its  dictates.