I agree with your distinction. You are not asking for better guardrails around assistant scaling—you oppose the premise itself. I would state the gender and power concern plainly but professionally: a predominantly female, licensed profession is being prevented from reaching its full scope while its core duties are transferred to an even less empowered and lower-paid workforce.

Dear Members of the Virginia Board of Dentistry:

I am a registered dental hygienist in California who previously worked as both a dental assistant and periodontal surgical assistant. I strongly oppose expanding the scope of dental assistants to include supragingival scaling with hand or ultrasonic instruments.

My opposition is not rooted in disrespect for dental assistants. Dental assistants are indispensable members of the dental team, and I deeply value their work. However, scaling is a foundational component of dental hygiene care—not simply the mechanical removal of visible calculus.

Safe and effective scaling requires comprehensive knowledge of periodontal anatomy, disease progression, calculus formation and detection, tissue response, restorative materials, instrumentation, and clinical contraindications. It also requires the judgment to recognize when inflammation or deposits extend below the gingival margin. The distinction between supragingival and subgingival calculus is not always visually or clinically obvious, particularly when a patient presents with bleeding, periodontal pocketing, recession, restorations, implants, root-surface exposure, or complex anatomy.

Ultrasonic instrumentation presents additional concerns. Safe use requires an understanding of power selection, tip design, adaptation, angulation, lateral pressure, water flow, aerosol management, contraindications, and the effects of instrumentation on enamel, root surfaces, restorations, implants, and surrounding tissues. Improper use may cause unnecessary pain, tissue trauma, surface damage, incomplete deposit removal, and a false appearance that appropriate preventive or periodontal treatment has been completed.

Dental hygienists complete accredited college-level education encompassing periodontology, anatomy, pathology, microbiology, pharmacology, radiology, patient assessment, medical-risk evaluation, instrumentation, and extensive supervised clinical care. We must demonstrate competency throughout that education and satisfy state licensure requirements before providing these services. Eighteen hundred hours spent working as a dental assistant, followed by limited procedural training and 20 supervised full-mouth scaling experiences, is not equivalent to that education, clinical preparation, or professional accountability.

I am also deeply concerned about the broader workforce implications of this policy. Dental hygiene is a predominantly female profession that has historically faced restrictions preventing its members from fully using the education and clinical abilities they already possess. In many states, qualified dental hygienists continue to encounter dentist-supervision requirements, limits on direct access, restrictive practice settings, and barriers to providing care independently in underserved communities.

Rather than removing those barriers and empowering licensed dental hygienists to address access-to-care shortages, this policy transfers one of our profession’s core clinical functions to a less extensively educated and lower-paid workforce that is also predominantly female and generally possesses even less professional autonomy. This does not represent meaningful workforce advancement. It risks deprofessionalizing dental hygiene, suppressing wages across the dental workforce, and preserving a hierarchical system in which highly trained clinicians remain restricted while their duties are reassigned downward for economic convenience.

Calling this an access-to-care solution does not make it one. Increasing practice productivity or reducing labor costs is not the same as expanding access to comprehensive care. There is no assurance that patients will be charged less, that underserved communities will receive more services, or that patients with periodontal disease will gain access to the licensed clinicians qualified to assess and treat them.

A patient who appears to need a routine prophylaxis may actually present with findings requiring comprehensive periodontal assessment and a different level of care. The person placing a hand scaler or ultrasonic instrument on that patient’s teeth must possess the education necessary to recognize those findings—not merely the technical training to remove visible deposits.

Patients deserve to know the credentials of the person providing their treatment. They also deserve care based on comprehensive assessment, sound clinical judgment, and demonstrated competency—not a fragmented model in which visible calculus is removed without the full education necessary to understand the disease process occurring around it.

I respectfully oppose the amendment of Guidance Document 60-7 and the inclusion of supragingival scaling among duties delegated to dental assistants. I urge Virginia policymakers and regulators to address workforce shortages by strengthening the dental hygiene workforce, expanding accredited dental hygiene education, improving recruitment and retention, removing unnecessary supervision barriers, and allowing licensed dental hygienists to practice to the full extent of their education.

The solution to limited access is not to lower the educational standard for clinical care. It is to fully utilize, support, and expand the licensed workforce already educated to provide it.

Respectfully,

Emily Wall, RDH
California