| Action | Training in infection control |
| Stage | Proposed |
| Comment Period | Ended on 3/4/2022 |
 |
16 comments
Virginia Board of Dentistry
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, VA 23233-1463
Dear Honorable Members of the Board,
Thank you for continuing the conversation to promote the safest environment for patients to receive quality dental care and advance the education for dental assistants. As this public testimony is open, I have just spent 3 weeks of instruction on infection control principles with newly admitted dental assisting students. This is such a strong foundation for the practice of dental assistants. An unclear understanding of the aseptic technique could result in cross-contamination and the spread of disease to patients, providers, and our communities.
As you consider all the comments that have been coming in over this topic, I would like for you to have insight into the different areas that are covered when we formally educate dental assistants about infection control. The topics include:
The typical on-the-job training for infection control is having a more senior employee show the new person how to disinfect a room or sterilize instruments when they are hired. There is no background understanding or critical thinking about what is actually being done and why. Unfortunately, this is not enough.
I have read the comments that have been put forth in opposition to this petition. I want to clarify just a few points. First, the Centers for Disease Control has no oversight authority. They only make recommendations for safe practice. If a dental assistant has no other training than what an office may share with him or her, how would they even know to use the CDC as a resource and for guiding principals?
Another point from others that is worth repeating is that the Occupational Safety and Health Act is an administration designed to protect employees, not patients. The Board of Dentistry is called to uphold the mission of the Department of Health Professions and that includes "ensure safe and competent patient care by licensing health professionals, enforcing standards of practice, and providing information to health care practitioners and the public ." This petition requiring minimal infection control training for dental assistants helps to advance the mission of ensuring safe and competent care and enforces standards of practice.
I leave you with this question, if everyone is already complying with infection control principles and practices why is there opposition to this? Wouldn't it be relatively easy for everyone to demonstrate compliance?
Respectfully submitted,
Misty L. Mesimer, MSCH, RDH, CDA
Dear Members of the Board,
As a CDA I could not imagine working in dentistry without the knowledge I have with infection control. With SARS-COV-2 still being present it is all the more reason to make it mandatory to be infection control certified, even if COVID goes away and or had never happened, there are still plenty of other transmissible diseases. If someone does not have background knowledge as to why we do a certain task, they are more likely to be more careless as they do not think of the repercussions that come to follow. Infection control not only protects our patients it also affects the dental assistant and keeping us and even the environment safe.
When you or one of your family members goes to the dentist, you want to feel at peace that the operatory was cleaned properly from the person before you. Passing this would ensure that feeling of cleanliness. Everyone could use to have more knowledge of their job and why we do what we do, making dental assistants infection control certified is good for them and everyone around them.
Respectfully,
Heather Bowling, CDA
Dental Assistants play a very important role in every dental office, but safety must always be the highest priority. Virginia requires radiation safety certification, but not infection control certification. Why? The lack of knowledge and understanding of how pathogens and infectious diseases are spread and how dangerous viruses can be, creates the opportunity for dental offices to be a breeding ground for HAI’s (Healthcare Associated Infections).
I have been an assistant since 1994, graduating from an accredited Dental Assisting program in Washington State. Washington State requires dental education in order to work in a dental office. I feel my education prepared me for my own personal safety and understanding of how many ways diseases can be spread. Based on my research, I know of at least 11 other states that have an infection control education requirement, with Maryland being one of them.
I have witnessed oral surgery instruments and hygiene instruments that are stored and autoclaved in a metal cassette being sterilized on the “pouches” setting. That’s 30 minutes less than the required sterilization time of proper sterilization of 35 minutes. All because they were unknowledgeable.
jEvery patient in every dental office is entrusting every DHCP (dental healthcare personnel) with their health and we as clinicians need to abide to that. And given the world we live in today, Virginia should be on the leading edge of patient and clinician safety.
I would like to comment on the proposal to require annual certification in infection control for dental assistants. Our office continues to hold infection control in the highest of standards. Every new employee is required to train in infection control first, before any other duties. If the state wants to require this then they should place the training online FREE OF CHARGE. Small practices like mine cannot continue to be taxed with these extra annual fees. Especially in this time of recovery. If the board considers this to be of utmost importance, then it should be available free of charge online so as not to burden practices with yet another cost.
I've been a dentist in Virginia for 15 years. I have no problem with this being a requirement. This will require the board come to an agreement about what is required with infection control, what is a recommendation and what is up to the dentist to decide (Example: Barriers are optional. Spore tests are required.) Ideally, like other states, you would provide an EASY to find link to online training and list everything required for the year. Keep it simple for everyone to follow. Other states have easy free online training for the other required CE such as opioid training.
Small practices are incurring more and more "monthly" or "annual" fees that are burdening us while insurance reimbursements have not increased at all. Newer monthly fees are amalgam separator fees, electronic prescription fees, etc.
Great idea. Keep it simple. Keep it free.
I have been a certified dental assistant for 4 years now. I have seen many assistants come and go with different levels of education. I have seen assistants that were trained on the job, assistants that had completed an unaccredited 4 month dental program, and I have also worked with certifed dental assistants. My observations concluded that the assistants that did not have an infection control requirement, did not grasp the importance of infection control. Infection control is more than just wiping down a chair with cavicide. Infection control is a very serious part of any dental office and if the assistants don't fully understand the importance of it, things will not be done properly and patients/ other employees will get hurt. Knowing proper knowledge about sterilization and disinfection is crucial for an assistant to be educated in. Becoming a certifed dental assistant gave me the knowledge that I needed to fully understand many things about dentistry, but most importantly infection control.
I believe it would be a disservice to our patients and employees to disagree with this petition for infection control training for dental assistants. Our occupational exposure to blood and OPIM on a daily basis would certainly warrant prior knowledge of bloodborne pathogens, appropriate disinfection and sterilization methods that are not based on what the last dental assistant demonstrated in the basic training of a new employee, appropriate PPE, what materials are considered contaminated and which must be disposed of in a regulated fashion as a minimum. I do recognize the cost factor for the dental practice as an issue and feel confident and hopeful that the Board can propose something that will benefit all parties involved.
Our dental assistants are already trained and retrained annually on infection control under OSHA guidelines. This testing is an unnessary burden.
I agree with the VDA position that this is redundant to require assistants to attend training on infction control. We already do this. As the practice owner it is my responsibility to train my team on infection control as well as HIPAA.
I agree with the comments made by the VDA President. This is another burdensome regulation which is already covered by OSHA and CDC guidelines, which the BOD already expects us to comply with. I especially agree with the "creep" of more state and federal compliance laws which will fall on the small businesses to comply and likely absorb the costs incurred.
I have worked in the dental field for 22 years and for the past 7 years have been responsible for training new clinical team members. I have conducted training for dental assistants newly graduating from 18 month programs, those trained on the job, and some who have worked in dental offices for decades. I have been consistently appalled at the lack of knowledge or misinformation followed by dental assistants in the area of infection control. I have witnessed a failure to correctly perform duties such as loading an autoclave, handling sharps, and disinfecting an operatory, putting coworkers and patients at risk and potentially causing cross contamination. There seems to be currently a lack of standardized training of infection control within the dental field (I experienced this myself prior to dental hygiene school). I feel it puts our team members and patients at risk. Therefore, I support the requirement of infection control training.
Below is an excerpt from Section V, subsection G ("Infection Control Education, Training, and Credentialing") in the ADAA Manual of Policies and Resolutions. It was amended in November 2021. The Executive Board of the Virginia Dental Assistants Association fully endorses this resolution and, respectfully, requests that the VA BoD propose, and support, the legislation required for its' implementation.“Dental Assistants are the dental team members who most often implement infection control protocols regarding, but not limited to, selection and maintenance of personal protective equipment, heat and chemical sterilization of dental instruments and handpieces, biological monitoring, surface disinfection, instrument protection, environmental asepsis, respiratory protocols, and handling and disposal of infectious waste… The American Dental Assistants Association advocates all Dental Assistants adhere to current Centers for Disease Control and Prevention recommendations and Occupational Safety and Health Administration and state regulations with documented proficiency in dental infection control protocols, and be it further resolved that the American Dental Assistants Association encourages the adoption of mandatory federal and state requirements for infection control education, training, and credentialing of dental health care workers.”
While I understand the intent of this new proposed regulation, I am opposed. Licensed dentists and their office team members are already held to high standards of infection control and therefore this is completely redundant. Redundancy in the form of government regulation undoubtedly will have additional costs associated with it and will therefore be passed along to patients. This unnecessary cost will continue to escalate the cost of dental care.
It seems prudent, in a science based profession, to provide and show evidence of state-wide infection control negligence in dental offices before justifying new regulations such as this.
This is an example of trying to solve a potential problem. Dentistry in Virginia has an excellent record of providing service through the years, despite Hepatitis, HIV, "Covid", etc. We even provided emergency care during the early phase of the pandemic successfully, without guidance from a third party.
The provision of allowing 60 days for the training is laughable to me. A new employee receives bloodborne, HIPAA, etc. initially. I don't want the liability of not doing it.
This, along with the Radiation Safety Course, aren't needed and are mainly supported by third parties for their financial gain.
Esteemed Colleagues,
I am writing to support the requirement for infection control training for dental assistants. I oppose the 60-day provision. The training should occur upon employment or before employment. Not requiring the training upon hire is gross negligence and can cause serious harm to our public if infection control procedures are not followed. Although they are told to "comply," they don't know the specifics of "how" to comply until the training/certification occurs.
Thank you for your consideration of this request and for the work you do on behalf of our citizens of the Commonwealth.
Sincerely,
Kelly Tanner, Ph.D., RDH
All healthcare professionals should be required to have formal training on infection control to protect patients and themselves. Infection control is the most basic and important part of a dental assistant’s role in a dental office due to their direct access to patients and potentially infectious materials. As someone with 28 years of experience as a dental assistant, hygienist, and educator, I have worked throughout the country and have seen egregious and frequent infection control breaches.
These infection control breaches are not done with malice, but due to a lack of education. The standards required to keep both staff and patients safe are not intuitive and must be taught. On-the-job training is often an uneducated team member teaching another uneducated team member and is not sufficient to protect patients or themselves. A thorough understanding of infectious diseases by dental assistants could prevent serious or even life-threatening cross-contamination.
Careers that require certification to work include: cosmetologists, nail care and eyebrow technicians, tattooists, cemetery salespersons, HVAC technicians, etc., why would dental assistants be different?
The public assumes a standard of care will be provided when having treatment in a dental office. If offices do not want to require their staff to be formally educated, they should be required to disclose that to patients. Patient and provider health should be the number one priority of all dental offices, proper education of the entire dental team is an essential component of creating a safe environment.