My concern with this proposed regulation is for the safety of the public. 

Learning to scale teeth requires an individual to participate in a minimum of 480 hours of supervised hands-on instruction. To  make the health and safety decisions involved with the invasive scaling procedure requires extensive additional study of associated topics in health sciences.

I attended 9 months of school to become a certified dental assistant.  My dental assisting education did not include scaling teeth.  Later, I attended two full years to learn to scale teeth as a dental hygienist.  The two allied dental healthcare roles provide very different and complemetary services for the dental health care needs of the Commonwealth.  

I can confidently say that the health outcomes for a patient scaled by a dental assistant will be more advanced oral disease; not less. This is a safety issue for dental patients.