As a future audiologist in this promising career, I strongly advocate for the revision of the existing emergency regulation on "limited cerumen management" to include what audiologists are meant to do, should be able to do, and have been successfully doing!

Simply put, cerumen removal has always been in the scope of practice for the field of Audiology. Audiologists provide service and care for every component of the ear and auditory system, why should it stop with ear wax? As a future clinician, the last thing I want to tell my patient is "you have too much wax for me to conduct any tests, you need to see a doctor first, then come back to me." Their response would make perfect sense: "you can look in my ears, stick probes in my ears, test my ears, put impression material in my ears, put hearing aids in my ears... shouldn't you be able to take something out of my ear?" The answer should be yes.

This issue takes an undermining turn when these patients are sent away to the doctor’s office, only to have a nurse (who did not study and train for 2-4 years in the field of ears, hearing, and audiology as an audiologist did) take the wax out themselves. Audiologists are already trained to be gentle, careful, and precise when working in and around the ear/canal. They already do more invasive services for patients, such as make ear-mold impressions, conduct Real Ear hearing aid measurements, and insert Lyric hearing aids, just to name a few. An audiologist should be allowed to (re)move wax/objects from the ear canal in order to achieve proper service for their patients. Also they should not be so strictly regulated as to when it is appropriate to do so. The extensive education that is required by the audiologist's degree should suffice as qualification that the audiologist can judge a situation to make the best and safest possible decision as to how to manage a patient's wax/foreign object.

The regulation restricts audiologists from conducting cerumen management for several conditions, all of which are either too conservative or are obvious enough to trust an audiologist's discretion to make the call against it. For example, if a patient can only hear out of one ear, that should NOT prevent cerumen removal, it should encourage it. I myself have a dead ear and a hearing ear, and I am VERY protective and nervous about anything happening to my one functioning ear. If I were to have total wax occlusion in my good ear canal, then imagine how much more trouble I would have hearing out of the only ear I rely on? If I had a foreign object in my good ear canal, then imagine how nervous I would be that it could cause damage to my tympanic membrane or something worse? As a person with single-sided deafness, I would WANT an audiologist to remove wax/foreign bodies EVEN MORE eagerly than if I had two working ears. As another example, if a patient has a foreign body in the ear, that should NOT prevent an audiologist from removing it. The object could cause harm to the patient if not removed, and who better to remove it than an audiologist or an ENT (hopefully not a nurse!). What if the object was something from the audiologist's clinic itself? Such as an earphone insert, ear mold impression material, or a hearing aid dome... it should be understood that an audiologist knows these items the best and is qualified to remove these items for the benefit and safety of the patient... it should also be understood that audiologists are smart enough to make the right decision as to when it is appropriate to do so.

The list of reasons goes on and on. As a future audiologist, my goal is to use my education and degree to service all my patients in the FULL scope of practice that an audiologist is responsible to uphold. That of course is including managing and removing wax/foreign objects for the benefit of my patients. I would be highly disappointed and discouraged (for myself and for my patients) to find out that the state of Virginia restricts me in this career goal.

Thank you for taking the time to consider my thoughts and opinions, especially as a student of the field.

Sincerely,

Sofia Ganev