As an out of state audiologist, I would like to humbly provide my comments for review.  I believe that the language currently proposed is too restrictive.  Audiologist are trained, and have the skills and clinical knowledge to assess the ear canal.  Cerumen management is less invasive in many cases than the insertion of a Lyric hearing aid or taking of an earmold impression.  I believe that patients safety is the most important issue, but in my area many primary care physicians have nurses or nursing assistants perform cerumen management under the doctor’s supervision.  Because many of the nurses are not properly trained for cerumen removal the practices as a result do not provide this service.  It then requires patient's to pay a specialist co-pay to see an ENT and often incur additional charges for flexible endoscopy as the ENT is now needing to provide a full exam for due diligence.  Audiologist are the most cost effective and properly trained professionals to be removing cerumen.  Please consider using broader language in defining the scope of practice, to allow audiologist to continue providing this much needed service.