As a certified dental assistant and a registered dental hygienist, I can speak from both sides.  I strongly oppose allowing dental assistants to scale subgingivally.  The education I received while attending dental hygiene school cannot be substituted, and it cannot be compared to the education I received while studying to be a dental assistant.  Countless hours were spent studying the human dentition, instrumentation, and subgingival anatomy, microorganisms, etc.  I spent two years studying 7 days a week to be a dental hygienist and passed an extremely difficult state board examination which is composed of several different parts.  I had to pass my state board to become licensed to perform subgingival scaling. 

To put things into perspective, a dentist must become licensed to perform procedures such as extractions, root canal therapy, restorations, etc.  As a dental hygienist, I know I can't be trained on the job or have a slight educational background in these areas and still provide patients a high standard of care.  It took dentists 4+ years to learn and apply these things to patient care.  It took me two years to learn dental hygiene techniques, such as subgingival scaling, and apply them to my patients.

All of the educational steps I took had to be taken to get me where I am today...a registered dental hygienist.  My patients appreciate my education and my experience.  These things cannot be "handed to" a dental assistant.  It takes years and years of practice and expertice to provide subgingival scaling to patients.  It is a very involved and delicate process.  My profession was initiated many years ago and has continued to evolve over the years.  Now it is being threatened and highly underestimated. 

I urge you to oppose scaling by a dental assistant II.  Thank you.