I strongly oppose expanding the scope of practice of dental assistants to include supragingival scaling with hand or ultrasonic instruments.

Scaling is not simply the mechanical removal of visible calculus. It is a clinical procedure that requires an understanding of periodontal anatomy, disease processes, instrumentation, tissue response, calculus detection, and the ability to recognize when deposits or inflammation extend subgingivally. The distinction between supragingival and subgingival calculus is not always obvious during treatment, particularly in patients with inflammation, periodontal pocketing, recession, restorations, or complex anatomy.

Dental hygienists undergo extensive accredited education and supervised clinical training specifically focused on periodontal assessment, instrumentation, prevention, and patient care. They must also satisfy licensure requirements before independently performing these procedures within their legal scope of practice. A limited training program and a required number of supervised scaling experiences are not equivalent to that education and clinical preparation.

I am especially concerned about allowing the use of ultrasonic scalers. Safe ultrasonic instrumentation requires knowledge of appropriate power settings, tip selection and adaptation, angulation, lateral pressure, water flow, contraindications, and the relationship of the instrument to the tooth and surrounding periodontal tissues. Improper technique can result in unnecessary tissue trauma, damage to tooth or restorative surfaces, incomplete calculus removal, and discomfort for the patient.

There is also an important issue of clinical judgment. A patient scheduled for what appears to be a routine prophylaxis may present with periodontal findings that require further assessment or a different level of treatment. The clinician performing scaling must be adequately educated to recognize those findings rather than simply remove visible deposits.

Expanding access to dental care is an important goal, but access should not be improved by lowering the educational standard for procedures that have traditionally required specialized clinical training. Workforce shortages should instead be addressed by strengthening the dental hygiene workforce, improving recruitment and retention, expanding educational opportunities, and removing barriers that prevent licensed dental hygienists from providing care.

Patients deserve to know that the individual using a scaler or ultrasonic instrument in their mouth has received comprehensive education in periodontal health, instrumentation, and recognition of disease, not simply abbreviated training in how to perform a procedure.

For these reasons, I respectfully oppose allowing dental assistants to perform supragingival scaling and urge policymakers and regulators to preserve scaling as a procedure performed by appropriately educated and licensed dental professionals.