With regard to the proposed emergency regulations to the Audiology License in the Commonwealth of Virginia:

I have been a licensed audiologist in California, Louisiana, and for the majority of my career, in Virginia.  I have been trained to remove cerumen decades ago by an otolaryngologist, and have refined my skills during the years working with other otolaryngologists and audiologists.   I can remove cerumen using suction, irrigation, and instrumentation (loops, forceps, etc.).   In addition, I have removed cerumen in newborns while performing newborn hearing screenings and have taught nurses and pediatricians how to remove cerumen in infants.  I have removed cerumen and foreign bodies from all ages and sizes of ear canals.  I have removed cerumen that was totally occluding a canal, patients with diabetes, previous ear surgery, and those on anticoagulants.

In 2006, while taking an Au.D. Course specifically on cerumen removal, one of my tasks was to survey the Board to find out if there were regulations.  I was verbally told, and emailed (not available now) that there were no regulations, BUT if an audiologist was trained to remove cerumen, it was allowable.  The Board trusted than an untrained audiologist would not attempt to remove cerumen and would refer appropriately.

In good faith, I have been providing this service for years.  I appreciate the Board’s desire to have a formal regulation in place within our licensure law.  However, what is proposed is rather limiting to those audiologists who do have training and experience.

For example, several physicians refer patients to me for cerumen removal, because they do not have the necessary equipment or time.   My community does not have a local ENT.  If every trained audiologist were to stop removing cerumen, this would be an inconvenience to many patients and even their physicians.  I wonder if any nurse, nursing assistant, medical assistant, and even primary care physician has the in depth training, experience and equipment that I do as an audiologist to remove cerumen.  Recently, a patient decided to have cerumen removed in their physician’s office.  The patient returned to me with pools of dried blood in each canal, reporting how painful it was.

I respectfully suggest that the severe limitations be removed from the proposed language.  Our board needs to trust that the licensed audiologists in the Commonwealth will ‘do no harm’ – respect our limitations and if we are not comfortable performing a procedure, refer out.

I personally do not have a problem requiring a consent form prior to the cerumen removal procedure, as this is standard practice in most medical/ para medical offices when any procedure is done.

Thank you for the opportunity to contribute to this proposal.

With regards,

Donna M. Mallory, Au.D., CCC-A