Opposition to Proposed Rule Permitting Dental Assistants to Perform Supra-gingival Scaling with Hand and Ultrasonic Scalers (§ 54.1-2701.1, C.1-2)

I am opposed to this proposed regulation, which would allow dental assistants — certified in-house by a supervising dentist rather than licensed through a Board-approved dental hygiene program  to perform supra-gingival scaling with hand and ultrasonic instruments.

1. Scaling is a clinical skill, not a task that can be certified in-house.
Dental hygiene education requires an accredited program of one to four years, including coursework in periodontology, oral pathology, pharmacology, medical emergencies, and radiography, paired with hundreds of hours of supervised clinical practice. Hygienists must also pass national and regional/state clinical board exams that specifically test scaling competency and the ability to recognize disease a scaling procedure might mask or worsen. A dentist-administered, in-office certification cannot replicate this depth of training or the ongoing continuing education requirements hygienists must meet to keep their licenses active.
2. Supra gingival scaling is not a purely mechanical or cosmetic task.
Even scaling limited to above the gumline requires differentiating calculus from other deposits and tooth structure, assessing periodontal status, recognizing early signs of active disease, recession, root sensitivity, or lesions, and modifying technique for medically compromised patients (e.g., those on anticoagulants, with cardiac conditions requiring antibiotic prophylaxis, or with uncontrolled diabetes). A practitioner without hygiene-level training in periodontal assessment may miss or misjudge these findings, delaying diagnosis and referral.
3. Patient safety and harm potential.
Improper use of hand and ultrasonic scalers can cause soft-tissue trauma, gingival recession, enamel or root surface damage, aerosol-related cross-contamination if infection control isn’t held to the same standard, and missed opportunities to catch periodontal disease progression. These are precisely the risks licensure and clinical board examination are designed to mitigate. Lowering the training threshold shifts risk onto patients who have no way of knowing their provider hasn’t met the same standard as a licensed hygienist.
4. Erosion of licensure standards undermines public trust.
Licensure guarantees the public a verifiable, consistent standard of competency. A parallel, lower-barrier pathway to perform a core hygiene procedure undermines that guarantee, creates confusion about who is treating patients and under what qualifications, and sets a precedent that could extend to more invasive procedures later.
5. Workforce concerns should be addressed without compromising standards.
If this proposal is meant to address access to care or staffing shortages, I’d urge the Board to instead consider expanding funding for hygiene education programs, streamlining license reciprocity between states, or exploring expanded-function assistant roles that don’t include scaling.
For these reasons, I urge the Board to reject this proposal and preserve supra-gingival scaling as a procedure restricted to licensed dental hygienists and dentists who have met the established educational and examination requirements.
Conchetta Brevard RDH,BSDH, MPH