I believe it is important for all dental assistants to have their radiation and health safety and their infection control. That way the dental assistants are aware of their surroundings and know how to protect themselves and others. 

Infection control is important enough to require certification. It's not just enough to know to wash your hands between patients and to wear a mask. We need to know how infection is transmitted and what needs to be done to prevent it. It's also important to know the effects of radiation and how to minimize it's exposure. Knowing that the staff at any dental (or medical) office is certified in infection control and radiation health and safety would give any patient peace of mind.

Me knowing what I know now from taking the Dental Assisting course being if I were a patient I would want any assistant working on me to be certified or to at least have the knowledge of both Infectious Control and Radiation Health Safety. I want to be able to walk into a office and now that I am safe because I am putting my life in someone else hands. So by me feeling this way I know my patients feel the same as well. They deserve the fairness and respect that I would want as a patient. So I agree.

It is a disservice to dental assistants and more importantly to the public, to have uneducated assistants that are ignorant to the dangers they are a part of each and every day as they provide care to the patient.  The Infection Control certification and Radiation Health Safety certification through DANB is a very logical approach to a solution.  I believe that if the public were truly aware of the critical nature of this issue,  they would have grave concern when seeking dental treatment.  The organisms we deal with in today’s world of healthcare in general are far more infectious and life threatening than those of the “good old days”.  I believe that our approach to this should no longer be one that was appropriate for the “good old days”.

I agree with this petition 

I agree 

As a former clinical dental hygiene instructor, I agree that the importance of both radiation safety and infection control protocol needs to be part of the entire dental team's education. 

If Virginia required credentialled assistants, this would not be necessary,as they would be tested in radiology, infection control, emergency procedures, and other areas.  Be proactive!!

Many DAs don't understand the weight of good infection control. This helps protect the public from there dangers that exist withbpoor infection control. The patient is our number one priority and this is a major component to his/her safety.

I agree with the petitioner's amendment.

A agree, however, instituting this for all the many assistants that have OJT would have to be advised to this. How would this be implemented? The schools (DA assisting, proprietary, and community college) would need to offer these certifications. The DDS would need to ensure that their staff was properly certified. I feel that hygienists have had many, many courses and yearly OSHA (BBP) updates yearly. Thank you 

Dental assistants need formal education to protect themselves and patients.  Dental assistants need more than just on the job training.  Infection control and Radiation Safety are just some of the courses all dental assistants should be required to take.  They should also have to take a test on the laws that govern the practice of dentistry so they know what is a delegable and nondelegable duty. 

As a long-time care provider and educator, I support regulation for dental assistants being certified in OSHA, infection control and radiation health/safety.  Additionally, the dental assistants should be current in their certification in Basic Life Support (BLS/CPR).  These areas of certification are a protection for the patient, as well as other members of the dental team.

At a minimum, dental assistants need formal education on Radiation Safety and Infection Control as well as CPR certification. Breaches of infection control are happening all over the country in all sorts of healthcare situations, and we need to gain control of this problem by making sure those people who perform these procedures most often in dental offices, the dental assistants, have the proper training. As for radiation health and safety, this training needs to be more than a few hours on radiation.  Most often, it’s the dental assistant in a practice taking the radiographs. Knowing proper sensor placement and tube head placement is as important as knowing how X-rays are generated to keeping the patient exposure level at the absolute minimum. The proper technique not only means reduced exposure but also proper diagnosis and treatment for the patient.  This law should pass without hesitation. 

As a former Dental Assistant, I am in favor to have all Dental Assistants be certified in Infection Control and Radiation Safety.  The CDC has recognized that one of the main duties as a DA is infection control. It is the utmost importance to protect our public and staff from the spread of disease. 

Agreed that knowledge in both areas is important. The Dental Assisting National Board (DANB) has offered certification for both Radiation Health and Safety and Infection Control for many years. Additionally, both of these exams are part of the CDA examination.

All Dental Assistants need to be certified for the protection of their patients as well as for their own protection and knowledge. 

As a former president of the VDAA back in the 80's I had been fighting for this for over 25 years before retiring. 

I highly recommend that the BOD finally makes this happens!

Thank you. 

Virginia T Dugge 

As a Certified Dental Assistant with 30+ years in dentistry, it is my sincere belief that having dental assistants properly trained and tested in radiation and infection control is vital to the health and safety of not only the patients and staff, but the community in general. This is a public health issue. Even a cursory search would reveal dozens of infection control breaches, affecting thousands, including deaths. These are not isolated "once in a blue moon" incidents. They can happen, and have happened, anywhere - dental schools, public health clinics, corporate and private practices, and more. Dental staff who know the how, what and why of pathogens and how to stop them are an absolute necessity in ALL dental practices. Please pass this regulation. Thank you!

Appropriate infection control procedures must be performed to ensure patient and staff safety. Following the CDC and OSHA guidelines for infection control can prevent or reduce the risk of disease transmission to patients and DHCP. With only 35k dental assistants who are certified in the US, this is a must to required dental assistants be certified in Infection Control in order to work in a dental practice. I have taught over 60k dental assistants in the US and this is the widest area of concern and clinical misunderstanding. We must protect our patients. Requirements for education should be the standard for every dental professional. I support this change

As a former DA and current RDH in VA, I strongly feel that DA's in VA should be certified in infection control with no grandfathering.  I continuously witness many incidents of cross-contamination in the dental offices by DA's, due to a lack of knowledge and training.

I feel that not only should DA's be certified in radiation health and safety, but the certification should include proper placement of film to prevent repeated exposure.

I recommend that the VA BOD votes in favor of this petition to keep the public safe.

Julie A. Martin, BSDH, RDH

I teach radiology and infection control classes to dental assisting students. Students have NO concept of infection control at the start of class, they touch their face and other surfaces with gloves on and then try to perform procedures on patients! This poses a huge concern for cross contamination. Radiology is also very important. Radiation causes permanent damage to tissues. If a student doesn't understand how radiation works they will not take seriously why it is so important to take images correctly the first time to minimize exposure to the patient. Dental assistants also need to have an understanding of radiology to help educate patients about why xrays are necessary and important....... patients try to refuse xrays all the time! 

Infection Control is the main duty of ALL dental professionals.   First and upmost, we must protect ourselves and our patients form contamination and diseases.  

I am writing in support of the proposed regulation change (petition 313) requiring dental assistants to be infection control and radiology certified through DANB or NELDA before they are allowed to practice in the Commonwealth of Virginia.  Having graduated from an accredited dental assisting program as a CDA in December of 2018, I am well aware that dentistry, like other medical fields, has its potential for health altering hazards.  My education and subsequent DANB certifications have provided me with the knowledge I need to protect my patients, myself, my team, and my community from injury and communicable disease.  An on-the-job trained dental assistant without certifications, however, will likely have no idea what airborne or bloodborne pathogens are, what standard precautions are, or even that there is a difference between disinfection and sterilization.  All of which are paramount knowledge in the avoidance of maleficence.  Patients and people, in general, have immense societal trust in their healthcare providers; dentists and their team members included.  Let’s not ever let anyone down!  Allowing substandard practice is unacceptable.  I ask you to please see the validity and criticality of this proposed change.  The patients and dentists in the Commonwealth of Virginia deserve competent certified dental assistants.

I am writing in support of the rulemaking petition proposing to require dental assistants in Virginia to pass the Infection Control (ICE) and Radiation Health and Safety (RHS) exams administered by the Dental Assisting National Board, Inc. (DANB) or to earn DANB’s NELDA certification.

The risk of transmission of infection in a dental office is a serious concern, and these concerns have been heightened by a series of high-profile breaches of infection control protocols reported in the media, including the following:

• In 2014, New Jersey public health officials discovered 15 cases of endocarditis linked to improper infection prevention procedures at one oral surgery office; of the 15 confirmed endocarditis patients, 12 underwent cardiac surgery and one died from complications of endocarditis and subsequent cardiac surgery.[i]

• In a highly publicized incident in Oklahoma in 2013, more than 4,200 dental patients required testing for infectious diseases after receiving treatment in the office of an oral surgeon whose staff was found to be using improper sterilization practices. Of those tested, 89 were positive for hepatitis C, with at least one of these cases confirmed through genetic testing as a patient-to-patient transmission of the disease.^[ii] Though it is unclear whether this oral surgeon’s assistants had any formal training or education, it is known that they did not hold DANB’s Certified Dental Assistant certification and had not taken DANB’s Infection Control exam, which is a component of the CDA certification.

At the time of the incident, Oklahoma did not have any laws or regulations requiring dental assistants to receive any specific education or training in infection control or to hold independent professional certification in dental assisting from DANB or any other entity. The supervising dentist, in a statement to investigators, indicated that he delegated all sterilization responsibilities to his dental assisting staff, yet the errors made by these assistants demonstrated that they lacked even a basic knowledge of infection control principles, including those on which they would have been comprehensively tested had they taken DANB’s Infection Control exam and/or been holders of DANB’s CDA certification.

• The Oklahoma incident described above followed a series of significant but less well publicized infection control breaches, including one in which more than 500 veterans were notified that they might have been exposed to hepatitis B, hepatitis C, and HIV after having procedures performed in a VA dental clinic where proper infection control protocols were not followed.^[iii]

In Virginia, there have been at least two allegations of breaches in the past two years, including one incident in which a dentist in a Richmond pediatric dental office informed patients that the practice’s one high-speed handpiece was not being heat sterilized between patients, but only wiped with an intermediate disinfectant. The practice is also accused of improperly maintaining water lines.[iv] In another case, a lawsuit filed in May 2019 alleges that employees/agents of a dental clinic owned by a company based in Roanoke used improperly sterilized instruments on at least 50 patients.[v]

The DALE Foundation, the official affiliate of the Dental Assisting National Board, Inc. (DANB), conducted a research study in 2016 focused on the value of dental assistants to dental practices. The cornerstone of the study was a survey that researchers circulated to dentists, dental assistants and dental hygienists in general dental practices; the survey included questions about delegation of duties to dental assistants.

The survey responses revealed the following related to delegation of infection control-related tasks to dental assistants:

• 69% of responding dentist and dental assistants indicated that “perform sterilization and infection control procedures” is one of the top five functions most frequently delegated to dental assistants
• 99% of responding dentists and dental assistants indicated that “perform sterilization and infection control procedures” is a function delegated to dental assistants; 28% indicated that this function was performed by qualified dental assistants, and 71% indicated that this function is performed by all dental assistants, including those who have not met any specific requirements[vi]

The consequences to the public of improper performance of infection prevention and control procedures can be very serious. Survey data indicate that dental assistants are performing sterilization and infection control procedures in 99% of general dental practices.  However, because Virginia does not regulate first-level dental assistants (Dental Assistants I), we don’t know how many dental assistants in Virginia do not have adequate training in infection control.

According to occupational employment statistics available from the U.S. Bureau of Labor Statistics, there were approximately 8,520 dental assistants employed in Virginia in May 2018. In January of that year, there were 2,400 dental assistants with Virginia addresses who had passed DANB’s Infection Control (ICE) exam since 1997, which is less than one third of all employed dental assistants. While it is possible that the approximately two thirds of dental assistants in Virginia who have not passed DANB’s ICE exam have received some type of formal education or training in infection prevention and control, there is simply no way to know. The good news is that, if Virginia adopts a requirement that all dental assistants must pass the ICE exam, approximately one third of assistants will have already met this requirement.

I am in full agreement with dental assistants being required to take DANB’s Infection Control Exam.  I have worked in dentistry in Virginia for 37 years as a clinician, a dental sales consultant, and an educator and administrator.  From my own experiences, I can say that the need for all dental assistants to be educated in infection control is crucial for the safety of dental professionals and our patients. 

I worked for 27 years in the same dental office. In my first few years as a dental assistant, I also thought infection control was not an issue, because the dental office where I worked employed highly educated dental assistants (including me) that believed in continuing education and maintaining current knowledge of the latest technology.  When I started temping as a dental hygienist on my days off, I realized that not every office maintained the same standards.  On several occasions, a dental assistant in the office where I was temping would give me an orientation to the office’s sterilization process and procedures, and I was frequently shocked at the deviations in best practices that I saw.

As a dental sales representative, I visited hundreds of dental offices in Virginia and had the opportunity to learn quite a bit about the way different offices operate. I wish I had kept a record of how many offices didn’t know the OSHA guidelines and the mandated rule to have office training in the bloodborne pathogens standard each year.  I am not aware of anyone checking to see if dental offices comply with this mandate.

Ten years ago, I became an educator and director of a dental assisting program that has four campuses located throughout Virginia.  This role has ignited a passion in me for the profession of dental assisting and reinforced my belief that there is a critical need for dental assistants who are properly trained and educated and who are certified.

My students all take and pass DANB’s Infection Control Exam before going on externship/internship and have demonstrated mastery of proper infection control concepts and procedures. They regularly bring stories back to class of appalling deviations from the best practices they have learned.  While I recognize these are second-hand anecdotal accounts, they cause me to be deeply concerned about the health and safety of dental patients in Virginia.  

In 2015, I served on the Regulatory Advisory Committee on the Education and Practice of Dental Assistants I and II.  The committee recommended that the Virginia Board of Dentistry adopt infection control requirements for dental assistants.  In the Board’s discussion, it was stated that there are no issues with infection control in Virginia.  I am certain that the Board members expressing this view were indeed following best practices in their own offices. But I am not aware of anyone checking or inspecting offices for proper infection control, and so I am not sure where the belief that there is “no issue” comes from.

To fully protect the public, I ask the Board to address the incorrect infection control protocols or disinfecting and sterilization issues that are happening all over Virginia by adopting a requirement that all dental assistants be required to pass DANB’s Infection Control exam. 

Regarding radiography requirements:

As of March 2019, 3,698 individuals had passed DANB’s Radiation Health and Safety (RHS) exam since 1997, representing less than half of all dental assistants in Virginia. This means that more than half of Virginia dental assistants have qualified to perform radiography procedures by passing the ARRT certification exam, which is not specific to dentistry and contains very little, if any, content on dental radiography, or by taking a course from a CODA-accredited program. Because many of the radiography courses offered in Virginia are themselves not accredited (though they may be offered by an accredited program), they do not follow a standard curriculum and there is significant variability in content, duration of hands-on instruction and assessment in these courses.

DANB’s RHS exam is a standardized exam, the content of which is based on a formal study to determine the tasks that are actually performed by dental assistants on the job and the knowledge that is needed to perform those tasks safely and competently. Dental assistants who pass DANB’s RHS exam demonstrate mastery of a standardized body of knowledge. Requiring DANB’s RHS exam for all dental assistants who perform radiography procedures will provide the Virginia Board of Dentistry with the means of verifying that dental assistants who perform radiography have the required knowledge to do their jobs safely.

I agree with the petition.