Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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6/19/20  1:40 pm
Commenter: Christian S. Tabor DMD, PC

Emergency standards and regulations from the Virginia Department of Labor and Industry (DOLI)
 
I am a General Dentist in private practice in Glen Allen, Virginia. I support the VDA request for an exemption from the proposed emergency regulations for the reasons stated in their letter. The following is some, but not all of their reasoning:
  • Dentists and oral surgeons in Virginia have restocked their supplies of PPE and implemented social distancing and other measures aimed at preventing the spread of the virus, consistent with the recommendation of experts in the dental field at the ADA and VDA 
  • Workplace settings for oral surgeons and dentists are already uniquely positioned to prevent and mitigate the spread of COVID-19
  • Regular use of PPE for oral examinations and procedures is current standard of care
  • Additional documentation and reporting requirements on top of the extensive measures already instituted would be overly burdensome and unnecessary 

Additionally, most (admittedly not all, but most) dental offices I know have taken extra means already to mitigate this virus as best as possible from having UV-C lights installed in our HVAC air returns to in the treatment room hepa filtration units with onboard UV-C.  We have even ordered an ULPA air filtration unit which guarantees filtration down to .8 microns - MUCH better than a HEPA filter.  We limit the number of patients that can be seen to allow time for cleaning between them and follow the CDC, OSHA, VDA, ADA recommendations already like installing sneeze-guards at the front desk and routinely wiping down all high use surfaces.  Adding more to do on top of these things will continue to overburden an already struggling system of businesses trying their best to get moving again.  Please exempt dental office from this rule - most of it we have done since we opened our practices 20 years ago.  Thank you.

Christian Tabor DMD

CommentID: 80882