I am writing in opposition to the petition for "on-job training" for dental assistants to become a DAII.  I have 14 years of experience as a dental assistant of which the last three years were as a DAII.  I have seen both on the job trained dental assistants and formally trained dental assistants and I can tell the difference in the quality of work between the two.  Those who have formal training do a much better job.  In my experience, the patients also notice the difference in terms of the quality of service provided, with those that have had formal training giving higher quality work as compared to those that have not.   I see this petition as a step back in terms of the safety of the patients and the quality of care; especially, when compared to the requirements in other states. I believe the loosening of the qualification requirements would be a detriment to the profession and the patients and would open the state up to legal liability when on the job trained DAII’s malpractice on patients.  Please do not deny the importance of formal education and maintaining high qualifications for the profession.  Dentists have years of formal education in addition to on the job training and standardized examinations in order to be allowed to provide dental care for patients.  If it is not acceptable for people to become dentists through on the job training and formal examination alone without the formal education, then it should also not be allowed for DAII’s.  We as dental auxiliaries should have our profession protected and the same logic applied in requiring formal, accredited education as with dentists in order to ensure the integrity of the profession and protect the patients from harm.  Patients deserve qualified knowledgeable dental care providers whether they be dentists or DAII’s.  Formal training as a DAII at school is an essential part of ensuring the integrity of the profession and to protect the patients from harm.  At school an instructor is dedicated to teaching and supervising their trainees without the pressure of working in their private practice where the doctor’s primary focus is on running their business and not training staff to perform complicated procedures on their own.  If anything, the solution to the shortage of DAII’s to encourage more educational institutions in the state to become accredited to training DAII’s.  The requirements to work as a dental assistant in Virginia are already less stringent than other states compromising the quality of care and safety of the patients.  Therefore, I ask that the requirements to become a DAII are not lessened, as it would prove detrimental to the patients health and allow for legal liability, but instead continue to allow those assistants that have taken the time and effort to be properly trained to give patients the excellent standard of care that is to be expected of a DAII. Thank you for your consideration of my comments and perspective.