I am concerned about potential changes to certification and regulation of surgical technicians. I am a plastic surgeon in Charlottesville, Virginia. I have been in practice for 24 years. During that time I have had wonderful surgical technicians that have had a varied background and training history. Some were trained on the job, some went through more formal ST programs, and of course an increasing few started as LPN/RNs. I have found that  proficiency at their job is less dependent on the initials after their name, and more dependent on their ability to understand the surgical process and anticipate the needs of the surgical team. Some go above and beyond their job description with help to the entire team. In my practice I have personally employed two surgical technicians that would go to the operating room with me and were individually employed by my, or employed by the hospital/surgery center in which I worked (as I am now employed). Both of these surgical technologists would no longer be able to certify under the proposed change. One in particular is a fantastic surgical tech that has gone on to train in additional first assisting and has been my "right hand"  in the OR. To lose such a valuable employee is a detriment to our community, particularly in the current hospital environment in which we are already severely short staffed. This particular pathway tends to be older techs so we would be selecting out the techs that have maturity, experience, and strong work ethic for younger, less experienced technologists. I am always willing to have students and new techs, but it does impact my surgical experience. Having reliable experienced techs in my cases is safer, and more efficient. To eliminate these through a random regulatory amendment without scientific backing is wrong. They should be allowed to continue to recertify and provide the same quality assistance they have been providing. Thank you for your time.