I am writing in support of the proposed regulation change requiring dental assistants to be Infection Control Certified (ICE) through DANB or NELDA before they are permitted to practice in the Commonwealth of Virginia. Having graduated from an accredited dental assisting program as a CDA in December of 2018, I am well aware that dentistry, like other medical fields, has its potential for health-altering hazards. My education and subsequent DANB certifications have provided me with the knowledge and credentials I need to protect my patients, myself, my team, and my community from injury and communicable disease. An on-the-job trained dental assistant without certifications, however, will likely have no idea what airborne or bloodborne pathogens are, what standard precautions are, or even that there is a difference between disinfection and sterilization; all of which are paramount knowledge in the avoidance of cross-contamination and subsequent maleficence. Patients and people, in general, have immense societal trust in their healthcare providers. That trust should be honored. The allowance of substandard practice is therefore unacceptable. I ask you to please see the validity and criticality of this proposal. The patients and dentists of the Commonwealth of Virginia deserve competent certified dental assistants. With COVID an ever-present threat these days, I can’t think of a more opportune moment to instate this change.

Thank you for reading my testimony and for your consideration of this very important issue. 

This proposed certification requirement will not benefit the public or dental offices. Any new dental assistant is trained under the dentist who has already received extensive training and is entirely capable of training a new assistant. COVID has shown that dental offices around the country are routinely doing an adequate job with sterilization as there hasn't been a single COVID outbreak traced back to a dental office anywhere in the country. Requiring a certificate that an assistant went to an assistant school will especially hurt dental assistants in rural areas that do not have access to an accredited assisting school. 

We already have OSHA training every other year to refresh the staff and doctors about proper sterilization protocols. Many assistants will be forced to pay for this certification themselves which will put an undue hardship on those who have the lowest income in a dental practice. 

If various infections disease outbreaks have been traced to improper sanitation of dental offices, I would support this bill. However, I feel the only group of people this will help are those who run dental assisting accreditation programs.

Misty L. Mesimer, RDH, MSCH, CDA

14 Little Street

Fredericksburg, VA 22405

March 11, 2021

Virginia Board of Dentistry

Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, VA 23233-1463

Dear Honorable Members of the Board,

Thank you so very much for advancing the petition requiring dental assistants to have certification in infection control procedures.  It is such a very important topic that needs to be addressed.  As we learn to live in a post-pandemic world being more mindful of aerosolized transmissions, you are demonstrating progressive thinking and action.  The importance of needing education and certification in infection control is evident in your decision last March to advance this petition.  I am writing now to discuss how we can operationalize this request. 

The easiest and most simple solution would be to say that all dental assistants must hold Certified Dental Assistant certification from the Dental Assisting National Board.  It would take all the work of certification and recertification off of your plate.  It would allow safe practice of dental assistants to be credentialed by a well-recognized and reputable organization that the Board can trust.  The Board would be assured of currency in infection control knowledge as well because maintaining the CDA credential requires annual education in infection prevention.  I strongly advocate for dental assistants to be Certified Dental Assistants.  This truly is a first step in assuring quality oral health care in our great Commonwealth. 

But I also recognize that we must navigate a regulatory system that has not always recognized the importance of formal education and credentials.  Those that have served in the role of a dental assistant without formal education and credentialling must be respected and honored.  The good news is that there are options for these professionals as well. 

As a first step, I recommend that we mirror regulations that are already in place.  The requirements for x-ray certification.  The language reads:” A dental assistant I or II shall not place or expose dental x-ray film unless he has one of the following: (i) satisfactory completion of a radiation safety course and examination given by an institution that maintains a program in dental assisting, dental hygiene, or dentistry accredited by CODA; (ii) certification by the American Registry of Radiologic Technologists; or (iii) satisfactory completion of the Radiation Health and Safety Review Course provided by the Dental Assisting National Board or its affiliate and passage of the Radiation Health and Safety Exam given by the Dental Assisting National Board. Any certificate issued pursuant to satisfying the requirements of this section shall be posted in plain view of the patient.” 

I propose that you create language for infection control certification that reads: “A dental assistant I shall not participate in clinical dental procedures until  (i) satisfactory completion of an infection control course and examination given by an institution that maintains a program in dental assisting, dental hygiene, or dentistry accredited by CODA; (ii) satisfactory completion of the OSAP-DALE Foundation Dental Infection Prevention and Control Certificate Program; or (iii) satisfactory completion of the Infection Control Examination provided by the Dental Assisting National Board. Any certificate issued pursuant to satisfying the requirements of this section shall be posted in plain view of the patient.”  Dental assistants who certify through any of these methods and do not maintain the CDA credential must have annual continuing education in infection prevention and control.  It is further recommended that dental assistants have until the next license renewal cycle to become compliant once the final language is approved. 

There have been so many stories of allied dental professionals not returning to their roles as they feared the unknown.  Requiring this level of entry-level credentials will help to grow the dental profession.  Dental assistants will be able to face the next pandemic with a strong base of knowledge.  They can proudly and safely serve because they understand disease transmission and prevention principles.  They will not need to rely on the media and political rhetoric to try and decipher best practices.  Doctors will have a well-informed assistant to help them navigate stressful and uncertain times. This will help to better serve the dental team and the patients. 

Dental assistants will be able to use this credential as a stepping-stone to a long career in dentistry.  There won’t be a temptation to go work at Starbucks where there the only aerosol is coffee grounds and steamed milk.  This will encourage relationship building with the patients of the Commonwealth and help promote the highest standards of care. 

Again, thank you for your attention to this important issue. Your decisions have the potential for positive impact both immediately and long term. 

Respectfully,

Misty L. Mesimer, RDH, MSCH, CDA

The responsibility for proper infection control policies and training lies with the dentist or practice owner solely.  A certification for dental assistants will be an extraneous requirement. Further, the targeting of the dental assistant community by the hygiene community is condescending and misplaced: if it is important for one portion of the profession it is important for everyone. This certification will duplicate the annual OSHA training, CDC guidelines, and place an undue burden on the dentist or practice owner.

The American Dental Assistants Association (ADAA) is in support of proposed Chapter Regulations governing the Practice of Dental Assisting (18 VA 60-30) Training in Infection Control.

In October 2020, the ADAA called on all states to recognize the importance of educating dental assistants in infection control. 

Our position recommends a minimum of 12 hours of didactic instruction in infection control and 4 hours of hands-on instruction to include skill evaluations that are signed off on by a licensed dentist for all dental assistants.  We believe that each individual State Board will know how best to serve the citizens of their state to keep them safe while in a dental office.

The ADAA believes that an educated dental assistant is an asset first and foremost to the public, then to the dental practice.  The ADAA offers course work for all dental assistants that covers several different areas of infection control, including waterline biofilm, handwashing techniques, placement of barriers in the treatment room and placement of personal protective equipment.

Please contact ADAA should you need additional information.  We would be pleased to discuss this issue further with you. 

This proposed certification places an undue burden on rural practices, where employees may have to travel long distances to receive training.  Dental office employees are already required to receive annual training in OSHA and infection control.  Also, dental assistants entering the workforce will feel compelled to seek training at their own expense, to be considered for employment. 

As a career dental assistant and now a dental assistant educator, I cannot express how important it is to have infection control training and certification.  I have had both on-the-job and formal dental assisting training. My OTJ training was sufficient for the time (1980s), but the current environment warrants more strict/stringent training in infection control.  Certification in Infection Control would go far in winning the trust of the public. Understanding the whys, as well as the hows, of IC makes a dental assistant very valuable and formal training and certification takes the burden off the doctor to do so.  Relying solely on annual OSHA training isn't enough to protect the public since OSHA protects the employee.   Thank you for your time and attention in this matter.

As a career dental assistant of 20+ years, who started as an OTJ trained assistant, I fully support this petition for certification in infection control procedures.  I was trained very well at a community health clinic who was accredited through JCAHO.  Unfortunately,  I found that after leaving the organization, the infection control training and annual OSHA training were not regulated and maintained the same in  offices that were not accredited through an organization.  I am from the poorest and most rural area in Virginia, the most southwest area of the state, and the education is available if you are willing to look for it.  The ADAA offers courses that train dental offices in infection control and meet DANB requirements. I am now a CDA, the team leader at my wonderful dental home, a member of the Advisory Board of the MECC Dental Assisting Program, and a current DAII student at GCC.  I have always believed that furthering education and attaining certifications are the best way to provide the best care for my patients.  My personal opinion is that all dental assistants should be certified through the DANB and maintain their certifications yearly by completion of CE credits.  This would allow the great State of Virginia to offer the best quality of oral healthcare to our patients.  Patients would recognize that their safety, and the safety of their practitioners has become of the utmost importance to us.  In this post pandemic world, patients are highly aware and inquire of the measures being taken to keep them healthy and safe.   I would hope that dental assistants that are currently practicing without a certification could easily complete such a course and sit for the DANB Infection Control Exam.  I would also hope that they would be willing to do this to further their knowledge and provide the safest oral healthcare they can to their families and communities.  I understand that this is only a first step and that there will need to be special circumstances that allow already practicing non-certified dental assistants a smooth and easy transition into attaining the certifications needed.   I am confident that the Board will handle this matter with respect and fairness to those assistants. I am excited for what this petition could mean for the growth of the practice of dental assisting.  Thank you for your attention and consideration to this petition.  

Summer Woodard, CDA

Big Stone Gap, VA 24219

The Board of Dentistry has already required that Dental Offices abide by the regulations of both the CDC and OSHA.

I practice in a rural community where trained dental assistants are a rarity. We must train our own assistants and formal training is not readily available.

Over the past 45 years I have had a number of high school students who have worked in my office. Several have gone on to be Dental Hygienists, RN's and one is now a dentist.

Having a requirement, as some have suggested, that no one could work as a dental assistant before having approximately 16 hours of infection control training at a formal setting is not reasonable. We lose and must rehire staff quickly in a rural practice.

Our Component (3) of the Virginia Dental Association has an annual meeting where we do OSHA, Infection Control and CPR Training.

I do not think that requiring dental assistants to be certified once a year will protect the health of the citizens of the Commonwealth of Virginia and instead lose employment opportunities to young Virginians.

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,

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.

I am a member of the American Association of Orthodontists, and I agree with the comments my association has submitted.

Denise Nguyen

I am opposed to the proposed regulations to require additional infection control for dental assistants. The current state laws already require dentist to provide and be responsible for proper infection control training of our staff. In our offices, we provide both CDC and OSHA training on an annual basis. We also have members of our team that are "compliance monitors" to make sure proper procedures and protocols are being followed at all times.
Additional training beyond what is already required would be a burden to our practice and be redundant.

Dear Ms. Reen and Members of the Virginia Board of Dentistry:

I write to you on behalf of the American Association of Orthodontists (AAO) in response to the Notice of Intended Regulatory Action (NOIRA) published in the Virginia Register on March 1, 2021 to take regulatory action regarding infection control for dental assistants I. We appreciate the opportunity to submit public comment at this time.

The AAO is the nation’s largest dental specialty organization and represents more than 19,000 orthodontists in the United States and abroad.  We have 396 members who are residents of, or licensed to practice dentistry in, the Commonwealth of Virginia. 

Currently, the Virginia Board of Dentistry’s (“Board”) Guidance Document 60-15 (updated December 15^th, 2018) titled, “Standards for Professional Conduct in The Practice of Dentistry,” indicates that it is the practitioner’s responsibility to, “Follow the applicable CDC infection control guidelines and recommendations. See https://www.cdc.gov/oralhealth/infectioncontrol/index.html.”

Furthermore, the Centers for Disease Control and Prevention (CDC) states that:

“Education on the basic principles and practices for preventing the spread of infections should be provided to all dental health care personnel (DHCP). DHCP include dentists, dental hygienists, dental assistants, dental laboratory technicians (in-office and commercial), students and trainees, contractual personnel, and other persons not directly involved in patient care but potentially exposed to infectious agents (e.g., administrative, clerical, housekeeping, maintenance, or volunteer personnel). Training should include both DHCP safety (e.g., Occupational Safety and Health Administration bloodborne pathogen and patient safety, emphasizing job- or task-specific needs.”

See, “Education and Training.” Centers for Disease Control and Prevention: Oral Health, https://www.cdc.gov/oralhealth/infectioncontrol/faqs/education-training.html

If the Board’s current Guidance is to follow the CDC guidelines, the AAO believes that necessary regulations should defer to the CDC or replicate CDC guidelines. The CDC also offers “Key Recommendations for Education and Training in Dental Settings”. Those recommends are as follows:

1.Provide job- or task-specific infection prevention education and training to all DHCP.

2. Provide training on principles of both DHCP safety and patient safety.

3. Provide training during orientation and at regular intervals (e.g., annually).

4. Maintain training records according to state and federal requirements.

See,” Administrative Measures and Infection Prevention Education Training.” Centers for Disease Control and Prevention: Oral Health, https://www.cdc.gov/oralhealth/infectioncontrol/summary-infection-prevention-practices/administrative-measures.html

The CDC guidance supports the notion of job-or task- specific education that can be done annually. Therefore, we feel that any infection control education and training required for dental assistants I should not create unnecessary burdens for dental offices given the limited scope of practice of a dental assistant I and the existing annual required Occupational Safety and Health Administration (OSHA) training. Requiring additional training would seemingly only be beneficial if the training includes some specific element related to the tasks of a dental assistant I that are not covered by OSHA training and CDC guidelines. Due to the limited scope of a dental assistant I, there does not seem to be any other task-specific infection control training that is not covered in guidance and training modules offered by OSHA or the CDC.

In summary, any DHCP in Virginia is already required to follow CDC and OSHA requirements, that additional regulation on infection control education and training required for dental assistants I should not create unnecessary burdens for dental offices given the limited scope of practice of a dental assistant I and the existing annual required OSHA training. Thus, the AAO advises against creating this additional regulation.

Thank you in advance for your consideration of these comments. Please do not hesitate to contact the AAO if we can be of any further assistance to the Board in its consideration of these issues.

Sincerely,

Trey Lawrence

Vice President, Advocacy and General Counsel

American Association of Orthodontists

As a member of the Va. Dental Association, I support the position expressed by VDA President, Dr. Frank Iuorno, which opposes a new regulation and certification process requiring dental assistants to receive additional training for infection control. 

This new requirement is already addressed and in place with everything we already are doing.  It is just an unneeded new regulation.  Dr Fuhrmann

I strongly oppose adding yet another training to the list of requirements.  At the bare minimum dental assistants are trained by their dentist employers who have been extensively trained in infection control.   That should be enough, but assistants are also trained in their dental assisting educational programs and in yearly OSHA trainings.  What is the science behind needing more regulation regarding infection control?  Have there been a large number of infections due to inadequate infection control?  Unnecessary regulations drive the good people away.  

There are currently extensive guidelines from both the CDC and OSHA related to infection control in dental offices. As of currently, I am unaware of cases originating in dental offices and therefore recommend against increased documentation of training for dental assistants which would lead to an unnecessary increase in costs to the patients.

I tried to find statistics that support the need for this additional training but was not successful.  This is already an annual requirement.  All new assistants are trained in this when they get their certification and annually thereafter.  If they are unaware of the infection control protocols and are having measurable issues with infection control, it is not due to a lack of training.  Adding another redundant training requirement will not solve this perceived problem. 

As a dentist that has practiced in the Commonwealth for over 30 years, I find this additional regulation to redundant in nature and it could have an adverse effect on access to care in a profession that currently has a shortage of providers in underserved communities.  Current regulations and requirements on the practice of dentistry in the Commonwealth  require adherence to OSHA and CDC guidelines.  Any additional regulation is unnecessary.

The newly proposed regulation for additional training is redundant and has no purpose. Infection control training is already accounted for extensively with the current CDC and OSHA guidelines which require such training on an annual basis; furthermore, these existing guidelines have proven to be successful as demonstrated by the fact that the State of Virginia has, as I currently understand it, reported no cases of infection contraction due to pathogen exposure in a dental office. 

The proposed new regulations requiring additional infection control training for dental assistants creates an unnecessary hurdle to becoming a dental assistant, especially in a COVID-19 world.  Dental employers have always been responsible for this training and adhering to OSHA and CDC guidelines.  We have done an exceptional job at this type of training and have had no issues with transmission.  We do not need additional regulation with red tape making it more difficult to hire and maintain employees.  

I think we have enough training to do already for us an our staff.  We made it through this Covid-19 year without any patient or staff member getting contaminated.  We do not need more unnecessary training of something we are already doing.

I am opposed to the BOD current proposal for redundant training in infection control for dental assistants in NOIRA Action 505. I believe the current Virginia regulations for infection control training thru CDC and OSHA guidelines are sufficient and further requirements by the BOD would be unnecessary due to the redundant nature.

Board of Dentistry,

I am writing in opposition to requirements that dental assistants receive separeate training and certification regarding infection control. The additional training would be redundant and unnecessary as it is already included in OSHA and CDC guidelines. 

In addition to my knowledge the state of Virginia has not had any reported cases of infection contraction due to exposure in a dental office. 

Thank you for your consideration. 

Peter Murchie dds

Additional requirements are redundant and not needed !

Dentists, dental hygienists, and dental assistants have already "stepped up to the plate" to deliver safe, quality dental care to the citizens of the Commonwealth by using OSHA and CDC guidelines to add to dentistry's already robust infection control procedures.  Acquisition or spread of Coronavirus in the dental setting has not been shown to be a problem.  Requiring "training" of dental assistants would be a redundant and unnecessary burden and have the unintended consequence of adding to the cost of dental care in the midst of a pandemic which is sapping the financial resources of both dental practices and patients.  

Due to the redundant nature of this type training from our annual OSHA classes and routine office discussions  about infection control , I feel this is redundant and unnecessary.

Thank you for your consideration

Additional requirements for Dental Assistants would be a waste of time  since everyone in the dental office should get this information through our required  yearly OSHA and CDC training.   Current laws already require dental offices to maintain exceptionally high standards for infection control.  Additional training isn't needed.

Hello,

I strongly oppose to the new requirements for dental assistants requiring additional training, as it would be reduntant and further more confusing. As Dentist, we are already adhere by CDC and OSHA guidelines for compliance, which include yearly training.

I appreciate you to reconsider imposing such redundant requirements for dental assistants. 

Thank you,

-

Milan Bhagat, DMD

As a dental practice owner and full-time clinician, I am very concerned all my staff maintain high infection control standards.   New staff receive initial training and all staff receive periodic and annual refresher training based on OSHA and CDC Guidelines.  I agree with the position of the VDA that implementing an additional layer of requirements would be redundant and hence, I am in opposition.

Respectfully, 

Michael L. Hutchings, DDS

To require additional training and certification for dental assistants would be unnecessary and redundant.  The Infection control protocols are dictated by OSHA and CDC requirements and guidelines.  This additional requirement would place a unneeded and additional burden on dental practices which have demonstrated exceptional compliance with current standards.  This is another layer of regulation which is already covered in current standards.  I do not feel this is necessary.

Respectfully, 

Tom Olivero DDS

This seems very much a redundancy of the training already mandated through OHSA regulatory protocols.  I do not see the benefit to this and places an additional burden on offices.  

I support the VDA presidents position and think that dentistry is doing a great job in infection control and is following OSHA and CDC to name a few.

I oppose the proposal for additional training requirement. 

I support the VDA President's letter opposing the proposed legislation for additional training for dental assistants. It has been covered by the CDC and OSHA guidlines and dentistry has done a fantastic job following these guidelines. More legislation would be redundant and an additional cost to dental offices when costs have gone up already during this COVID crises. 

Richard W Bates DDS

After reading over the comments I feel Dr. Keith Vaughn's position is of merit. The training is there and available. Mandating more training will not solve a perceived problem and only add more burden to all providers without benefit to the public. I do not support this measure.

I oppose this proposal, as this is an unnecessary burden for dental assistants. The regular OSHA training performed gives the dental assistant a good fresh up of their knowledge annually. An extra course would be -especially for dental assistants who live and work in more rural areas- unnecessary for an experienced dental assistant.  

opposition to proposed additional training for dental assistants

I am strongly opposed to the newly considered requirements for dental assistants.

I DO NOT support additional regulation on infection control education and training for dental assistants.  This creates unnecessary burdens on our practices when we already have extensive training required for our assistants to meet existing OSHA and other infection control requirements.

Respectfully,

A B Hammond III DDS

Orthodontist

Lexington VA

I am opposed to additional certification in infection control for Dental Assistants.  Dental offices adhering to OSHA  and CDC guidelines train all of their staff (hygienists, dental assistants and administrative staff) on a regular basis how to protect themselves and their patients.  This certification process would be a costly  and unnecessary.  I have not heard of any problems in dental offices with the current training requirements.

I oppose additional separate certification and training of dental assistants in infection control practices. I find it redundant in the fact we are required to train according to CDC and OSHA standards and spend many hours training annually to comply.

To date there are no reported cases in the state of infection due to pathogen exposure in a dental office.

I have read comments in support of this regulatory proposal, which goes back a few years. The comments do not include specific cases, or research, that demonstrate problems with the existing requirements or support this redundant regulation.  The support is from organizations, educators, and individuals that would benefit financially from the regulation.  The result of the regulation would further reduce the already small number of applicants for DA positions, and complicate the already expensive and time consuming process of on the job training for new employees, and employment of part time DAs. The result would reduce clinical time,  and raise the overhead cost for dental offices, and probably reduce the total number of DA in the workforce. 

My clinical team have all been with me for 12 to 20 years. They are already frustrated with our repetitive quarterly retraining in Infection Control, OSHA, HIPAA, Emergency management, CPR, etc.  I have benefited from several DAs with DANB certification in my practice. Other excellent DAs have considered DANB, with my support, and ruled it out for a variety of personal and financial reasons. Many DAs do not have the patience or interest to take a lot of classroom courses, and to force repetition of overlapping training yearly is frustrating and a waste of their time. I do not see how  patients would benefit from this addition of redundant training requirements. It would certainly reduce the time we have to provide their dental care.

I strongly favor the infection control requirements for DA 1 in Va.  During  this time of covid and any future outbreaks, it is essential that proper training is given to help stop the spread of viruses and diseases to our staff and patients.  

As a CDA I believe dental assistants should have infection control training. Without this proper training we leave room for cross contamination this is even more important with COVID-19 and many other viruses. Operatories need to be properly cleaned before the next patient arrives as well as the instruments and waterlines being properly maintained and cleaned. We are putting our community and families more at risk by not having dental assistants trained in infection control. 

It is important for the assistant to have the infection control certificate as they are with the oatients more, and should have the updated information.  Thank you

As a licensed dentist in Virginia for more than 33 years I have seen a significant increase in regulatory requirements imposed by the Board of Dentistry, many of which have had my support.  The proposed requirement for additional specific training for dental assistants in the area of infection control is unnecessary and redundant in my opinion because regulatory requirements for the entire staff are already in place.  Initial training for dental assistants is regulated and required, and annual re-training requirements have existed for years in order to satisfy OSHA and CDC policies and procedures.  The dental industry, in general, provides one of the least hazardous workplaces in the health care sector and there are few if any instances of illness transmission documented from a dental healthcare setting.  Additional regulatory burden on dental practitioners is not necessary in this regard, and serves to contribute to the consumer cost of dentistry in Virginia.

   I support the act to require Infection Control certification among DAs. As a current certified dental assistant, I have met many DAs that have been assisting in the office for many years, yet have never taken any accredited education courses relevant to the dental field. As a result, many new DAs that have been hired without certification are limited to understanding what they are taught in that office. I've noticed this creates assistants that do what they're told, without a full understanding of the why's and how's. The DA spends a lot of time with the patients and is expected to be fully knowledgeable. The patients are trusting our knowledge. 

   The current pandemic has complicated and strained many. Why not move on with professionals that are strengthened in how to handle infectious diseases for the future? 

I oppose this NOIRA to regulate additional training needed for dental assistant I's. These employees are already required to go through extensive training to meet OSHA and CDC requirements. Additional training needed would create an unnecessary burden for practices in Virginia. In addition, it could pose difficulty for practices in more remote areas of the state to meet these requirements.