The  7 audiologists in our practice are in agreement with the previously submitted comments regarding the proposed excessive regulations regarding cerumen management by audiologists.

Under Definitions, Section B.  This rule indicating  that an audiologist can only remove cerumen in the outer 1/3 of the external canal is inappropriately restrictive since audiologists have extensive training in making earmolds and placing impression materials to the 2nd bend in the canal.

The contraindications listed in Section C are excessive:

These litmus tests for contraindication would require the audiologist to get out the regulations each time before proceeding with a simple cerumen management procedure.  Licensed audiologists trained in cerumen management are certainly qualified to judge whether they can successfuly remove cerumen or whether the patient needs to be referred to ENT for this procedure.  The board need not legislate and/or itemize these  contraindications.

Section D:  Why should the audiologist be required to have written consent from the patient  for cerumen removal?  If the audiologist has the appropriate training, this procedure is no more invasive than other audiological procedures which do not require written consent. 

Respectfully submitted:

Danny W. Gnewikow, Ph.D. Audiologist, FAAA, CCC

Nancy V. Bradsher, Au.D., Audiologist, FAAA, CCC

Lauren B. Stone, Au.D., Audiologist, FAAA, CCC

Kelly M. Camarda, M.Ed., Audiologist, FAAA, CCC

Kara M. Martin, Au.D., Audiologist, FAAA, CCC

Hope A. Middlemas, B.S. Provisional Audiologist, and 2015 Doctorial candidate

Lisa M. Schultz, B.A., Provisional Audiologist, and 2015 Doctorial candidate

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