Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Dentistry
Regulations Governing the Practice of Dental Assistants [18 VAC 60 ‑ 30]
Action Training in infection control
Comment Period Ends 3/31/2021
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3/27/21  10:11 am
Commenter: Walter E Saxon Jr

Against Unneeded Regulation

I am against the Board of Dentistry requiring dental assistants to be certified by another agency for infection control, etc.  The dental assistant (DA) works under our license.  We are already required to provide training in Blood Borne Pathogens, HIPAA, etc.  This includes infection control.  I doubt that any standardized test would be specific enough to cover each individual office.  In essence the proposed regulation would still result in the individual office being sure that the DA is trained for that office.  We've been doing this for all employees for many years, not just DAs.  Infection control, etc. is an office endeavor.  There have not been any instances that I'm aware of infection control causing a problem in dental offices, even though we are in a pandemic, that is different from previous ones (avian and swine flu).

This also poses a hardship for dental offices who need to hire a dental assistant.  The majority that I've hired through the years don't have experience and we train them.  Requiring them to pass a test by another entity first is a hinderance to allowing us to provide safe, quality dentistry in an efficient manner.  The first item on their first day is about the risks of bloodborne, etc. as we want them to remain healthy, which is connected to infection control (part of OSHA requirements).  A required state test would not relieve dentists of their responsibilities and if a new assistant was to be regulated by the Board of Dentistry, it would probably mean that we would have a harder time filling the position.  This could potentially result in our insurance premiums going up.

Years ago, at a statewide meeting of regional planning district commissions, the director of the BIGS Center of John Tyler CC was talking about their ability to increase revenue due to state regulations.  The first example was the "Radiation Safety Course".  This proposal seems to me to be in the same category.  I don't see any benefit in either one and would welcome the Board of Dentistry declining to require DA to get any other training other than what is already required by state and federal regulations.  It would be even better is they would study and see if there are any advantages in the "Radiation Safety Course".  It was implemented over 40 years ago and x-rays have undergone many improvements through the years.  One teaching institution has a sign saying that the machine is low radiation and shielding is not required, but will be used if requested.  It seems that this requirement has outlined it's usefulness, but not been deleted.  That's the problem with regulations and laws, their relevance isn't reviewed and updated as needed.  Don't add another.

CommentID: 97437