Has there been any study to indicate that such a new, broad training requirement for dentists/staffs would have saved the lives of those people that died?  There are plenty of solutions out there in search of a home as we've experienced from the dental supply industry.  The true costs in time and dollars and the benefits of a bureaucratic approach do not seem to be a wise investment to me.  The buying -in by the leaders of the dental profession, without exposing the strategic costs, is unwise in today's litigious society with a political leadership that is actually looking for ways to cut costs.  I see this as just another step down the road to making the dental operatory into a surgical suite in the face of a favorable cost/benefit analysis that is not there. There is an ongoing regulation of the solo practitioner out of the profession, for no good moral reasons other than the pursuit of a political power game that having dentists on a Regulatory Board is intended to avoid, thereby protecting all concerned in a strategic sense.

Recommendation: The Board to table this request without action unless it can disapprove it outright, with a solid cost/benefit analysis that exposes the strategic negatives to the proposal, if that analysis would be required due to the political nature/tailwinds of this proposition.  I am even reluctant to outlay dollars for such a study to start down this path.  My only real concern here is how much effort will be needed to head off this "progressive" movement in the face of all the realities "on the ground"? 

I am uncomfortable with givng this sort of proposal any support so that other future Boards might leverage even any minimal support now into a larger movement in the future. The dental societies and the medical insurance industry, on their own, are probably the best proving grounds to provide the current, appropriate level of  training without a heavy-handed regulatory approach.

Thank you for allowing this consideration in this forum and for the important and difficult work you do in your advisory efforts to be an honest broker between the public and the dental profession.