Agency
Department of Health Professions
 
Board
Board of Dentistry
 
Guidance Document Change: Amendment to 60-7 to include new delegable tasks for dental assistants as provide by statute
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9/3/26  10:18 am
Commenter: Elizabeth B

Opposition to Dental Assistants Scaling
 

To the Members of the Board of Dentistry,

I am writing to respectfully express my opposition to allowing dental assistants to perform dental scaling without the level of education, clinical training, and competency required of licensed dental hygienists.

Dental hygiene is a specialized profession that requires extensive education in areas such as anatomy, periodontology, pharmacology, infection control, radiography, patient assessment, and the recognition and treatment of periodontal disease. Scaling is not simply a task that can be added to a dental assistant’s responsibilities without appropriate education and clinical preparation. It requires the ability to assess a patient's oral health, recognize disease, understand medical and dental histories, identify potential complications, and provide safe and appropriate treatment.

Expanding the scope of practice for dental assistants to perform scaling may appear to be a solution to the shortage of dental hygienists, but I do not believe it addresses the underlying problem. If there is a shortage of qualified dental hygienists, we should focus on solutions that increase access to properly educated and licensed hygienists rather than lowering the educational and training standards for providing preventive and periodontal care.

There are other ways to address the demand for dental hygiene services, including expanding dental hygiene education programs, increasing opportunities for students to enter the profession, improving recruitment and retention of hygienists, and exploring other responsible workforce solutions.

Most importantly, patients deserve to receive care from professionals who have been appropriately educated and clinically trained to provide that care. Maintaining high standards for education, competency, and licensure protects both patients and the integrity of the dental profession.

I respectfully ask the Board to carefully consider the potential consequences of allowing dental assistants without appropriate dental hygiene education and training to perform scaling procedures. I strongly encourage the Board to prioritize patient safety and pursue solutions to the hygienist shortage that strengthen, rather than reduce, the standards for dental hygiene care.

Thank you for your consideration and for your commitment to protecting the public and maintaining high standards of oral healthcare.

Respectfully,
Every Registered Dental Hygienist

CommentID: 241042