Dear Ms. Knachel and Members of the Virginia Board of Audiology and Speech-Language Pathology,

I am an audiologist with over thirty years of experience in various settings, the last twelve in a private practice setting.  I am concerned about several items on the Emergency Regulations for Cerumen Management.

The first is Section C, Item 2, which states a "perforated tympanic membrane" as a contraindication to audiologists performing cerumen management.  Impedance testing, whcih is readily availably in audiologists' offices but often not readily available in physicians' offices, can easily be used to help determine the presence of a perforated tympanic membrane.  Therefore, it is my opinion that Section C, Item 2, a "perforated tympanic membrane" be removed as a contraindication to any cerumen management for audiologists.

Section C, Item 7 lists diabetes mellitus, HIV infection, or bleeding disorder as contraindications to audiologists performing cerumen management.  It would seem that well-controlled diabetes would not be a contraindication to cerumen management for the audiologist since the canal membranes would be strong and intact and not especially vulnerable.  So, I would ask that diabetes mellitus be removed from the list of contraindications to audiologists performing cerumen management. 

Section C, Items 10 and 11 state that cerumen impaction that totally occludes the ear canal, or the inability to see at least 25% of the tympanic membrane is a contraindication to audioologists performing cerumen management.  In order to do our primary job, which is evaluating hearing, we must have a clear route for the test tones to travel.  To interrupt the hearing appointment for the patient, who often has difficulty travelling, to go to a physician's office for cerumen management is cumbersome at best and at worst is fragmented care.  Often, the personnel in physicians' offices who actually do the cerumen management are much less well-trained to perform cerumen management than aduiologists.  They are responsible to learn and perform various procedures on the whole body, whereas audiologists are limited to and specialize in the ears only. Therefore, audiologists, in general are much better prepared and have much more experience working with ears than health professionals who must divide their time and experience over the entire body.  Also, frequently physicians refer their patients to audiologists for cerumen management because of the audiologist's expertise and experience in this area.  And so, I would submit that audiologists are the profession of choice to remove impacted cerumen and cerumen which covers more than 25% of the view of the tympanic membrane.

Please consider the concerns mentioned above and remove Section C, Items 2, 7, 10, and 11 as contraindications for audiologists performing cerumen management.

Elizabeth C. Anderson, Au.D.

Doctor of Audiology