I am writing in response to the addition of scaling to the duties delegated to a DAII. I have seen several dentists comment that the reasoning for this is a shortage of hygienists. I don't know where they are located but I work in Roanoke and we have a surplus of hygienists. There are few job openings now and when there is one, it is usually part time. Hygienists are licensed for a reason, the type of care we provide is specialized. If it was just about scaling, then just get a monkey, put scrubs on it, hand it a scaler and let it go to town. It's just not that simple. Are you going to require that they have 15 CE hours a year to educate them about the constantly evolving correlation between periodontal disease and systemic disease and the everchanging types of scalers and techniques? What if there is a 3mm pocket with 3mm of recession? Are they going to know how to scale the root without gouging it? There is a reason we are required to complete at least an Associates Degree before we can practice. There is a reason we complete 3 different board exams to become licensed. One dentist's comment I read was that they already scale cement from a recently cemented crown. I've got news for him, newly set cement is NOT more tenacious than calculus. I've removed supragingival calculus that laughed at the ultrasonic scaler I was using, so don't tell me cement can be more tenacious than calculus. Maybe if it's been there for several years, but you and I know it only takes maybe 5 minutes for cement to harden enough to remove it, and even then it's not more tenacious than calculus. Also, would the DAII know the difference between calculus and the CEJ, an enamel pearl, or restorative margins? And, when you think about it, supragingival scaling is a misnomer. Calculus is rarely exclusively supragingival, especially if it's interproximal, unless the tissue is blunted, which would negate the Class I classification because blunted interproximal tissue is usually a result of current or past periodontal destruction. Our patients deserve the high quality of care we provide and allowing the DAII to scale is negligent at best. As far as trying to lower the cost of dental care, you get what you pay for. One of the assistants I work with said she would not feel comfortable scaling because the training would essentially be done on the job. Scaling is irreversible, you can't go back and redo it if you make a mistake like you can with an xray for instance. Please vote for our patients safety instead of the bottom line, which we know is what this is all about. Thank you for your consideration of this matter.