I agree with Robin Knopp's statements and would like to emphasize that this an attempt to erode our authority to make decisions about the ability of personnel we have trained to perform a procedure.  I am the one who is responsible to train my staff and the one who is accountable if they are not meeting the standard of care required.  Dental scaling is not a highly skilled procedure and several people on my staff have the ability to be trained for this. It is always done under my direct supervision and then all the teeth are checked by me.  Part E of the this section states:          "The veterinarian remains responsible for the duties being delegated and remains responsible for the health and safety of the animal."  We as veterinarians are well aware of this responsibilty and our judgement needs to be trusted.

Microchiping has already been addressed in guidance document 150-4.  Animal shelters and other groups are now microchiping pets at the time of adoption and at clinics they hold at other times of the year like the recent rabies clinics  (which by the way is against the regulation). To restate in the regulation that "animal shelters may inject animals while in their possession"  will only add confusion to the issue.  What is their possession?

I agree with the previous posted comments regarding the proposed narrowing of the permissible duties of veterinary personnel.  I am a veterinarian in a practice that promotes excellent dental exams and therapy, since it is so important to the overall health of our pet patients.  This change to regulations may actually prove detrimental to consumers and their pets.  I will explain my reasoning after a brief summary of the current procedures  (for  non-veterinarians).  Under anesthesia a thorough exam of the mouth is conducted,  tooth or gum problems are charted and a plan of action for therapy is prepared.  My dental assistant then removes the largest deposits of tartar with a hand tool prior to ultrasonically scaling the visible surfaces of the teeth.  This process may take 20-30 minutes during which time I am able to perform any other procedures needed for the pet.  After scaling is complete I will review the mouth tooth by tooth and address any problems that exist (need for dental X-rays, caries, mobile teeth, deep gum pockets, fractured teeth, tartar under the gum line).  After therapy is complete, my assistant  polishes the teeth, then rinses, dries and seals the tooth surfaces.      

      Except for the anesthesia, this sounds like going to the human dentist!  Minimizing the time under anesthesia dictates that we be very efficient.  If a veterinarian is required to perform all aspects of the dental procedure, then he will need to charge for his time rather than an assistant.   The time under anesthesia will typically be longer as any additional procedures planned for the animal will need be done sequentially not coincidentally.  The increased costs for the veterinarian's time and the prolonged anesthesia will mean many owners will be unable to afford it. Their pets will suffer.  (Note that I have neatly side-stepped the issue of the lack of veterinary technicians to fill this role, but even there, the cost factor is present.)

     Training and supervision of veterinary assistants in proper use of hand and ultrasonic methods is straightforward and is the responsibility of the veterinarian.  Major points for instruction include: use a light touch with the tip of the ultrasonic scaler (the sound waves gently vibrate away the attached tartar); don't stay on the same tooth for more than 10-15 seconds at a time as this can build up some heat ; leave any suspicious teeth, gum problems,  or tartar under the gum line for the veterinarian to tackle.  Changing these regulations would increase the costs and  anesthesia times (the riskiest part of the procedure) and would ultimately result in decreased level of care for many animals.  "Above all else, do no harm"  is our veterinarian's creed---follow its  dictates.

I am deeply concerned about the proposals included in 18VAC150-20-172 line 8, as I feel such a change will be a detriment to pet owners.

To require licensed professionals to perform this technique will necessitate a tremendous increase the the price of dentals to clients.  In turn for families facing financial issues, many pets will not receive the medical care they require.

I also am not certain if this measure would set the mandated standard of care higher for veterinary patients than for human patients. 

Unless there exists a mounting body of evidence that this procuedre is being performed improperly by unlicensed staff, I feel passage of such a measure is detrminental to the delivery of veterinary care. 

Sincerely,

Dr. Andrew Silverstone