I have read comments in support of this regulatory proposal, which goes back a few years. The comments do not include specific cases, or research, that demonstrate problems with the existing requirements or support this redundant regulation.  The support is from organizations, educators, and individuals that would benefit financially from the regulation.  The result of the regulation would further reduce the already small number of applicants for DA positions, and complicate the already expensive and time consuming process of on the job training for new employees, and employment of part time DAs. The result would reduce clinical time,  and raise the overhead cost for dental offices, and probably reduce the total number of DA in the workforce. 

My clinical team have all been with me for 12 to 20 years. They are already frustrated with our repetitive quarterly retraining in Infection Control, OSHA, HIPAA, Emergency management, CPR, etc.  I have benefited from several DAs with DANB certification in my practice. Other excellent DAs have considered DANB, with my support, and ruled it out for a variety of personal and financial reasons. Many DAs do not have the patience or interest to take a lot of classroom courses, and to force repetition of overlapping training yearly is frustrating and a waste of their time. I do not see how  patients would benefit from this addition of redundant training requirements. It would certainly reduce the time we have to provide their dental care.