NADL Submission to ADA Workforce Task Force

March 31, 2005

Jon Holtzee
Director, State Government Affairs
American Dental Association
211 East Chicago Avenue, 21st Floor
Chicago, IL 60611

Submitted by email to: holtzeej@ada.org

Dear Mr. Holtzee,

Thank you for your letter requesting comments for the work of the ADA Workforce Models Task Force. On behalf of the National Association of Dental Laboratories and the National Board for Certification in Dental Laboratory Technology, we are pleased to submit the following commentary.

1) How might new technologies in dental laboratory technology require a new dental team member in the dental office? Do you anticipate that future innovations will require additional specialized training for members of the dental workforce?

The future of in-operatory cad/cam systems will create a need for a dental technician team member who will have enhanced computer skills, design skills, material knowledge and skills in patient care. With the continued integration of CAD/CAM technology both currently in use within the dental operatory and dental laboratory, the need for dental team personnel to have adequate skills in computer processing and equipment usage will be of importance.

Additionally, the use of digital imaging and the electronic transfer of such information between the operatory and laboratory will foster a more efficient communication process that will require a knowledge of treatment planning and recordkeeping and patient privacy protocols. The efficiency of utilizing digital photography and imaging can even include digital impression taking, which will require additional clinical skills on the part of the technician. This will greatly improve the ability for continual and open communication between the operatory and the laboratory regardless of the geographic span between the two offices.

With the advent of dental assistants making adjustments to prosthesis and the emergence of dental hygienists having expanded duties/functions in some states, the need for positive interaction by all members of the dental team on restorative dentistry will be imperative.

2) How do you envision technological change will alter the provision of dental prosthesis over time?

Again as discussed in question 1, both the increased use of CAD/CAM technology and digital imaging will foster greater efficiency and productivity in the manufacture of dental restorations. The need for individuals to serve as dental technicians will continue, however, it is likely that the range of skills needed to be successful in the occupation will change as further technological advances are available in the dental technology market.

It is an exciting opportunity to attract new types of individuals into the occupation due to the computer aided manufacturing aspects and their clinical applications for dental technicians that come with some of the new technologies.

There is a need to eliminate barriers to patient care within dentistry; this is directly from the ADA’s Research agenda.

3) A trend affecting dental laboratory technicians has been the referral of work to off shore labs. Do you see this as a continuing trend: What workforce modifications can be made to modify this tide?

The workforce modifications that could be made to level the playing field beyond existing regulations would be an acceptance of technician certification as a part of state dental practice acts such as the model that exists in Texas statutes.

The existence of off shore/foreign competition in dentistry relative to dental laboratory restorations is nothing new. However, the increase in the volume of restorations has fostered a new awareness on the subject from the industry, the dental profession and the government. It is highly unlikely that a system of tariffs on imported dental restorations would ever come to fruition like you have with other industries nor is the NADL supportive of such governmental barriers.

However, the oversight of foreign dental laboratories relative to imports coming in to the United States have and will see increased enforcement. The U.S. Food and Drug Administration, Centers for Devices and Radiological Health has the authority to inspect foreign dental laboratories and has authority to hold shipments at port. Additionally, the agency requires both foreign and domestic dental laboratories to comply with Quality System/Good Manufacturing Practices as addressed in the Code of Federal Regulations, Part 820.

The inspection activity of the FDA will generally focus on both the foreign dental laboratory entities and their U.S. broker agents defined as “initial distributors” under FDA registration classifications. There are current requirements for proper disclosure through labeling to inform the dental client where a restoration is made.

Under labeling requirements, a laboratory must indicate point of origin in the following manner: 1) “Manufactured by XYZ Dental Laboratory, Shanghai, China or 2) “Distributed by XYZ Dental Laboratory, Anywhere, USA”. The key words are manufactured by or distributed by. In essence “manufactured” indicates the laboratory location where the restoration was created.

It is important for dentists to inquire of their dental laboratory if they are FDA compliant and utilize a quality assurance process.

There is no formal regulation that suggests that a dental client must disclose the point of origin information to the dental patient. Conversely, there is no restriction on a dental client voluntarily sharing such information with the patient.

4) What opportunities are available to enhance recruitment efforts in the field of dental laboratory technician?

Both the NADL and the ADA have “Careers in Dental Laboratory Technology” videos/DVD’s available to promote and explain the occupational requirements and job growth opportunities of the profession of dental technician. The NADL and ADA products are autonomous relative to the content; however, each covers the general skills necessary for the occupation, the potential salary/earnings information, the day-to-day duties and a discussion of the work environment of a dental technician.

The ADA’s video/DVD is available for purchase by any member of the public and is intended for broad distribution to high school guidance counselors, high school HOSA chapters and other secondary school venues of that nature.

It is important to note that some state dental societies and state dental laboratory associations have independent and joint programs at the state level that are geared toward promoting “careers in dentistry” to the same secondary school market. In Florida for example, through the efforts of the Florida Dental Health Foundation, a program exists called Project SELECT. As part of this program’s mission, is the existence of a program manager that travels the state conducting career presentations in secondary school settings promoting “careers in dentistry” with an emphasis on dental assisting and dental laboratory technician.

The NADL works annually with the U.S. Department of Labor on updating the occupational handbook information on the profession of dental technician. This information is included in the master handbook for all occupations, which are available at most secondary schools, vocational schools, colleges and universities and public libraries.

One significant barrier for recruitment of individuals into the field of dental technology is the lack of public awareness that the occupation exists. This is in large measure because in all but three states there are no mandated certification requirements for individuals to be dental technicians. Further, except for a minority of states that allow out of office shade verification, it’s rare that a dental patient would ever meet or interact with the dental technician.

An important opportunity that is available is to provide a political environment that would foster expansion of formal recognition of the “Certified Dental Technician” designation in state Dental Practice Acts. This could be accomplished by requiring a dental laboratory to employ a certified dental technician in each specialty area provided by the dental laboratory in order to operate. This would elevate the public presence of the occupation and provide a recognized value of those dental technicians that enhance their verified knowledge and applied skill through written and practical testing and annual continuing education.

The popularity of cosmetic dentistry that has been enhanced by reality shows such as “Extreme Makeover” have provided a forum for public awareness that the dental technician and the dental laboratory is a valuable member of the dental team serving the dental patient through thoughtful treatment planning by the dentist.

We appreciate the opportunity to provide formal comments for the Task Force and look forward to continued interaction on issues related to dental laboratory technology. If our organization(s) can provide additional materials we are poised to do so.

Please feel free to contact me at 1-800-950-1150.

Sincerely,

Bennett Napier, CAE
Co-Executive Director