March 25, 2021

Dear Members of the Virginia Board of Dentistry,

The Virginia Board of Dentistry does not need to regulate infection control training for DAs.  First, the Virginia Dental Hygiene Director's Consortium should not be initiating a petition for rule making that affects the Dental Profession as a whole.  They should certainly make that recommendation for their own membership should they feel the need.  As dental professionals with advanced education and training, Dentists are more than qualified to ensure that their DAs are effectively and competently trained in infection control procedures.  This is in fact the case as evidenced by the Board’s finding that there have been no reports of infection spread in the state of Virginia by an untrained dental assistant. This finding alone should negate the need for an added regulation...case closed.  Otherwise, we are now subjected to proposed regulations based on a perceived issue, rather than on the scientific data. In addition, the Board makes the case for relieving the owner/doctor from all infection control accountability with the following statement: “Since dental assistants I are not regulated by the Board, the dentist is accountable for infection control practice, but it is often the dental assistant who is responsible for infection control processes and procedures.”  So, by regulating DA infection control training, one can only assume that the Board now feels that it wants to take on the added responsibility for monitoring dental assistant training and disciplining them when standard infection control procedures are not followed.  This would also seem to have the negative effect of releasing the overseeing Doctor from having any accountability for the infection control procedures implemented in his/her office possibly increasing the number of infectious diseases spread by poorly supervised infection control procedures.

In summary, I think the Board’s decision to consider regulating infection control training for DAs is shortsighted and an overreach by the Board.  The mere fact that this proposal was not even put forth by the community of professional dentists shows the lack of need for this type of regulation.

I respectfully request that the Board reconsider implementing such a regulation.

Sincerely,