NADL Fights Unskilled Technician Label
NADL Fights Unskilled Technician Label
October 29, 2010
Teri Morisi, Branch Chief
Division of Occupational Outlook
Employment Projections Program
Bureau of Labor Statistics
Room 2135, 2 Massachusetts Avenue NE
Washington, D.C. 20212
(202) 691-6501
Dear Chief Morisi,
I am writing to you on behalf of the National Association of Dental Laboratories which represents dental laboratories and dental laboratory technicians classified as 51-9081 under the 2010 SOC. We are submitting written comment to the Federal Register notice of September 29, 2010 relative to the proposed education and training classification system.
Our association is submitting comments relative to the following element specified in the notice:
The clarity of the new system of assigning education, previous work experience, State licensing and on the job training categories to each occupation.
Dental Technicians are currently classified as: MOG E—Precision Production, Craft, and Repair Occupations, Precision Workers, Assorted Materials (E678 Dental Laboratory and Medical Appliance Technicians).
This group includes occupations involved in the fabricating, processing, inspecting or repairing of material, products or structural units. Incumbents must have a thorough and comprehensive knowledge of processes involved in their work, usually acquired through apprenticeship or intensive training. Workers must exercise considerable independent judgment and must usually display a high degree of manual dexterity.
It is our organization’s contention that Dental Technician should fall under the MOG A Technical classification.
This MOG includes occupations concerned with the study, application, and/or administration of physical, mathematical, scientific, engineering, architectural, social, medical, legal statute, biological, behavioral, library, and/or religious laws, principles, practices or theories. Some occupations are concerned with interpreting, informing, expressing, or promoting ideas, products, etc. by written, artistic, sound or physical mediums. Certain occupations that provide support in all of the above fields are included in MOG A. Most MOG A occupations require educational preparation.
MOG A also includes technical occupations. These occupations are involved in carrying out technical and technological functions in health, engineering, science, and other disciplines. May perform research, development, testing and related activities. May operate technical equipment and systems.
At the federal level, dental laboratories are regulated by the FDA as manufacturers of finished dental (medical) devices. As manufacturers of medical devices, the dental laboratory and laboratory personnel are subject to FDA regulations.
The regulation relevant to the technician and dental laboratory is: Title 21, Part 820 of the Federal Food, Drug, and Cosmetic Act of 1978.The quality system regulation stipulates that manufacturers (laboratories and technicians) of medical devices (dental restorations) “must establish and follow quality systems to help ensure that their products consistently meet applicable requirements and specifications.”
The greatest depth of knowledge for the technicians is assessing the feasibility of meeting client (in this case, dentists) requirements for custom-made dental devices. In order to establish the dentist requirements, the dental technician must have a comprehensive understanding of dental anatomy, occlusal relationship and material science. This knowledge is generally gained by formal education.
“Title 21, Part 820: Design Review Qualifications Guidance states: Formal design reviews should be conducted by person(s) having technical competence and experience at least comparable to the developers.” It is at this stage of the manufacturing process that the dental technician ‘assesses the adequacy’ of the ‘design – the R/X’ for the dental device. During the last twenty years, dental schools have reduced the number of clock hours in restorative dentistry. This has facilitated an environment whereby dental technicians are called upon to serve as subject matter experts on dental material science and selection, case management and case design.
The transition of occupational classifications from the previous DOT system to O*Net has resulted in dental technicians being downgraded from a higher SVP to a lower SVP. The classification for dental technology is now Zone 2. The DOT identifier was SVP 7. If we look at the effect of the re-classification, our profession has gone down two slots.
The SVP categories refer to the total training time (Education, Training and Experience) required to perform the job duties.
o Job Zone 1 = SVP below 4.0
o Job Zone 2 = SVP 4.0 < 6.0
o Job Zone 3 = SVP 6.0 < 7.0
o Job Zone 4 = SVP 7.0 < 7,9
o Job Zone 5 = SVP 8.0 and higher
The previous classification indicated dental technicians needed advanced special skills for the workplace and the current classification to Job Zone 2 indicates dental technicians only need a high school education.
It’s important to note third party verified statistics from our profession that clearly dispel that notion. In several industry surveys, conducted by the National Board for Certification for Dental Laboratory Technology, www.nbccert.org, market research indicates dental technicians hold and need formal education.
The NBC is an ANSI accredited certifying body that administers the examination process for “Certified Dental Technicians”, CDTs. This designation is the only certification for dental technicians recognized by the American Dental Association and is required in some state dental practice acts, in order for a dental laboratory to operate or do business in that state.
In the most recent NBC survey, 29% of the dental technicians had some college training, 31% held at least a two year associates degree in dental technology, 7% held other associates degrees, 14% held a Bachelors degree and 6% had a Masters degree or higher. Clearly, the re-classification transition did not take into account actual market data that consistently shows the need for formal education to be a dental laboratory technician.
Another factor that contributes to the need for education and training for dental technicians is the integration of CAD/CAM, computer aided design/computer aided milling. Dental technicians in today’s environment routinely design dental restorations using this type of technology.
Additionally, the use of digital imaging and the electronic transfer of such information between the dental operatory and dental laboratory require a higher level of skill and knowledge as it relates to treatment planning, recordkeeping and patient privacy protocols.
In summary, several key points necessitate the Department of Labor re-evaluate the classification of dental technicians under the O*Net system from Zone 2 to at least Zone 3.
These are:
- Dental technicians manufacture “medical devices” and as such are regulated through quality system regulations by the U.S. Food and Drug Administration
- Independent market research indicates the majority of practicing dental technicians hold education of at least community college level or higher
- A Certified Dental Technician designation is required by some state dental practice acts in order to operate a dental laboratory. This designation requires at least 5 years of experience and or education before an individual can take the examinations.
- CAD/CAM technology utilized by dental laboratories requires unique skills and knowledge for today’s dental technician. In many cases, dental laboratories are now hiring technicians with a computer science and or engineering background.
- With the documented absence of appropriate dental technology education as it relates to fixed and removable prosthodontics in most dental schools, dentists have become more reliant on dental technicians as an expert in this science and a valuable team member in patient treatment.
We appreciate the Department of Labor’s review of our request and recommendation. If additional reference material is required or desired please feel to contact NADL at 800/950-1150.
Sincerely,
Bennett Napier, CAE
Co Executive Director
Cc:
Chris Waldrop, CDT, President
Ricki Braswell, CAE, Co Executive Director
Elizabeth Curran, CDT, DT, Arizona School of Dentistry
Reference Documents with examples of dental laboratory technician hierarchy:
NADL Competency Standards www.nadl.org/pdfs/NADLCompetencySt.pdf
NBC Certification Categories http://www.nbccert.org/
NBC Module Categories
http://www.nbccert.org/modularization/index.cfm
USAF Laboratory specialty training classifications
DENTAL LABORATORY SPECIALTY, AFSC CFETP 4Y0X2
Headquarters US Air Force, Washington, DC 20330-1030
http://dentalpdf.tripod.com/cfetp4y0x2.pdf
Federal Government Position Classification
Position Classification Standard for Dental Laboratory Aid and Technician Series, GS-0683 http://opm.gov/fedclass/gs0683.pdf
Commission on Dental Accreditation:
Accreditation Standards for Dental Laboratory Technology Education Programs http://www.ada.org/sections/educationAndCareers/pdfs/dlt.pdf
