The change in 18VAC60-20-195, which no longer allows unlicensed individuals to satisfactorily complete a course and pass an examination in compliance with guidelines provided the board, should be reconsidered.  There is a large need in the State of Virginia for competent individuals to place and expose intraoral dental radiographs.  These individuals cannot expose dental radiographs without the knowledge on how to safely use ionizing radiation for diagnostic purposes.  To meet this large state-wide need, accredited dental hygiene programs should be able to give a course on radiation safety protocols and dispense radiation safety certificates to those individuals who pass an examination.  Other opperating feilds with radiation exposure have simular requirements and dental radiography should be no different.  Please protect the public and ensure that proper testing of healthcare professionals is mandetory when exposing the public, including children, to ionized radiation. 

Thank you,

Tara Newcomb

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There is a lot of confustion concerning the change to this regulation based on the phone calls and emails I have received in my office since May 11th.  The new regulation states in part (iii) "satisfactorily completed a radiation course and passed an examination given by the Dental Assisting National Board".  I believe the confusion is the part that addreses "radiation course".  Is it the online course offered by DANB or courses previously offered by various institutions in the state? I think it would help if the BOD would clarify this part of the regulation.  If the decision is made to allow short radiation courses to once again be offered in the State of Virginia, then it may be feasible that only CODA accredited programs would be authorized.  CODA accredited programs have always followed strict standards concerning radiology within their existing curriculum. These standards are required by the ADA. These same standards matriculate down into the shorter versions that have previously been offered.  I personally feel that challenging the DANB radiology exam certainly is an excellent idea but it must be remembered that the exam does not have a hands-on practical portion. The exam is only offered in a written form or by computer.  Dental offices will still be required to give instruction on exposing and processing x-rays to new employees.

In reading the 18VAC60-20-195 Radiation certification regulations, I am presuming that;

(i)                 satisfactorily completed a course or examination recognized by the Commission on Dental Accreditation of the American Dental Association (A CODA approved dental assisting/dental hygiene/dentistry   program and passing the approved final exam). 

(ii)               been certified by the American Registry of Radiologic Technologists (Military trained dental assistants).

(iii)             satisfactorily completed a radiation course and passed an examination given by the Dental Assisting National Board (Non-CODA-accredited dental assisting/hygiene program and passing the DANB RHS EXAM). 

In my opinion all three pathways teach Radiation Safety for patient and operator, processing, mounting, labeling, and exposure/evaluate techniques.  New regulation (iii) certainly needs to be addressed.  Does this also mean that the two day Dental Radiography courses that were provided for years in Virginia by several dental assisting and dental hygiene schools are still approved as long as the DANB RHS Exam is taken and passed?  I believe this is the issue that needs more clarification.  Also, the DANB RHS EXAM can be taken without any prior education or experience (no eligibility requirements).  Is this accepted?  It is of my opinion that the DANB RHS EXAM is very comprehensive and you must be extremely knowledgeable to pass it.