I am writing to respectfully express my strong opposition to allowing dental assistants to perform dental scaling procedures without obtaining Registered Dental Hygienist (RDH) licensure in the Commonwealth of Virginia.

Dental scaling is not simply a mechanical procedure. It is a clinical service that requires comprehensive education and hands-on training in periodontal assessment, disease recognition, instrumentation, infection control, anatomy, pathology, radiographic interpretation, and patient safety. Registered Dental Hygienists undergo extensive accredited education and clinical training, followed by state and national licensure examinations, to demonstrate competency in these areas.

As a licensed dental hygienist, I believe there is an important distinction between assisting with dental procedures and independently providing services that fall within the professional scope of dental hygiene. Allowing individuals without the education and licensure required of an RDH to perform scaling could create inconsistencies in the standard of care and potentially place patients at risk. Proper periodontal care requires more than the ability to remove deposits; it requires the knowledge and clinical judgment to identify disease, recognize abnormalities, assess treatment needs, and determine when a patient requires further evaluation or referral.

I also believe that expanding the ability to perform scaling to individuals without RDH licensure diminishes the importance of the education, clinical training, and professional standards required of licensed dental hygienists. These requirements exist to protect the public and ensure that patients receive care from appropriately educated and qualified professionals.

Virginia should continue to prioritize patient safety and quality of care by maintaining appropriate educational and licensure standards for dental scaling. If scaling is to remain a component of preventive and periodontal care, it should remain within the scope of appropriately licensed dental hygienists who have been specifically educated and evaluated for competency in providing these services.