Status Change - Dental industry fights the government's recent downgrade of labor status for dental technicians

The NADL also notified the American Dental Association (ADA), American Dental Education Association (ADEA), and Council on Dental Accreditation (CODA) of the proposed system and its potentially devastating effects.

“The far-reaching impact this could have on the dental laboratory industry is immense,” says Bennett Napier, co-executive director of the NADL. “From obtaining state workforce development grants and recruiting overseas technicians to maintaining and funding our 19 accredited educational programs and attracting young people to this profession—all of these areas and more would be severely affected if the downgrade from skilled to unskilled status is allowed to stand.”

The downgrade occurred when the Department of Labor replaced the Dictionary of Occupational Titles (DOT) and its Specific Vocational Preparation (SVP) standards with the Standard Occupational Classification system and a new Occupational Information Network database (O*NET).

The SVP standards (Table 1) had been used for nearly 50 years to define the specific vocational training necessary to achieve adequate performance for each occupation. The new Standard Occupational Classification system has condensed the 12,740 job classifications from the old DOT system to just 822 occupational types. Several job titles that had identified advanced preparation in the old SVP rating system were also downgraded when converted to the new classification system.

“Dental technicians under the old DOT system were classified as SPV 7, which consists of workers who require 2 to 4 years of education to adequately perform their jobs,” says Elizabeth Curran, CDT, RDT, the NADL-nominated commissioner and chair of the CODA Dental Laboratory Technology committee.

When the DOT classification system was converted to O*NET (Table 2), dental laboratory technicians were reclassified as SVP 4. Then, SVP 4 educational skills were downgraded to the new Job Zone 2 classification, which only requires a high school education and includes occupations requiring more than 3 months, but no more than 1 year, of occupation-specific training.

So what does all this mean? The impact will be staggering if the new classification system is left unchanged, Curran predicts. At the most basic level, the downgrade means that high school career counselors will not recommend dental technology as a career choice to graduating high school students. For students currently enrolled in dental technology programs, completing the 2-year program still means they will be recognized by the government as unskilled laborers—falling in the same category as printing machine operators, shoe and leather workers, and jewelers. Curran says there would be little incentive to keep dental technology programs funded and in operation, let alone to develop new programs to educate those who are now rated as an unskilled workforce.

It would also likely impact mid-size and larger laboratories looking to take advantage of state grants for workforce training. The medical device manufacturer status once used to obtain those grants would likely be disputed, based on the threshold of educational criteria and training needed for an unskilled industry. “Laboratories that once qualified would no longer be able to,” Napier says. “To stay competitive, laboratories need to take advantage of every open door for state or federal funding—this downgrade would close those doors.”

The ability to recruit foreign-educated technicians to the US would also be affected. The Immigration and Naturalization Service (INS) classification follows the occupational criteria set forth by the Department of Labor. “As it stands now, we can claim there is a supply-and-demand issue for highly trained and educated technicians, due to reduction in workforce numbers and the reduced number of dental technology educational programs,” Napier says. “But if the unskilled classification stands, then the INS would be hard-pressed to grant entry for a class of workers now deemed by this country as replaceable by high school graduates needing only 3 months to a year of training.”

In light of projections that 11,000 technicians are expected to retire or leave the dental technology industry in the next 5 years, the potential fallout is worrisome, Curran says.

“If we do have a mass exodus of formally-educated technicians, we need to have a bracketed and immediate source of educated technicians to take their place,” she explains. “If those doors are closed as a result of this reclassification, the industry in this country is in huge trouble.”

Some foreign-trained technicians have already been denied entry into the US, Napier says. An immigration attorney was recently telling him that the INS denied entry to a South Korean technician with 3 years of college education and 2 years of apprenticeship in a laboratory, citing the recent change in labor status. “It’s black and white to the INS,” Napier explains. “They only go by the labor classification codes established by the Department of Labor.”

Where we go from here is critical. In the written comment it submitted to the Federal Register and the Bureau of Labor Statistics on October 29, the NADL argued that the FDA considers dental laboratories to be manufacturers of finished dental (medical) devices, and thus subject to FDA regulations (Title 21, Part 820 of the Federal Food, Drug, and Cosmetic Act of 1978). Those regulations stipulate that medical device manufacturers “must establish and follow quality systems to help ensure that their products consistently meet applicable requirements and specifications,” and that “formal design reviews should be conducted by person(s) having technical competence and experience at least comparable to the developers.”

The letter goes on to discuss how dental laboratory education for dental students has eroded in US dental schools, resulting in the need for dental technicians to “serve as subject matter experts on dental material science and selection, case management, and case design.”

Napier says a precedent has already been set by other occupations that experienced a downgrade in labor status and were shifted back up, based on factual information provided by the leadership within the occupational group. One of the NADL’s strongest arguments in its letter to the Federal Registrar included statistical results from the most recent survey conducted by the National Board for Certification for Dental Laboratory Technology. Nearly one-third (29%) of technician respondents have some college training; 31% have at least a 2-year associate’s degree in dental technology; 7% hold other associate’s degrees; 14% have earned a bachelor’s degree; and 6% have obtained a master’s degree or higher. Another issue is that some state Dental Practice Acts require a laboratory to employ a certified dental technician in order to operate a business within the state.

In addition to submitting comments, the NADL has corresponded with Arlene Furlong from the ADA’s Council on Dental Practice and Richard Valachovic, DMD, MPH, president of the ADEA. Both organizations are likely to submit a letter of comment in support of reversing the status downgrade, Napier says.

At the annual American College of Prosthodontics meeting in November, the Prosthodontic Forum also voted to respond to the reclassification. “Because this is a federal issue, we also need to have a congressman weigh in on behalf of our industry,” Napier says. “We are working with a local congressman in Florida to write a letter in support of an occupational upgrade.” The deadline for submitting comments was November 30. With that step completed, the NADL can lobby to have the labor status downgrade reversed and original status reinstated.

Even if the reclassification is overturned and technicians are reinstated to their former Job Zone 4 status, Curran sees other changes that need to take place to further protect the industry.

She believes it is critical to modify the new O*NET American Community Survey, a yearly online public survey designed to replace the 10-year census and collect timely data on occupational skills, knowledge, work activities, education, and job training. Within the survey is a list of educational landmarks indicating the degree of education obtained. However, there is no provision for vocational education, which could be devastating for those who have graduated from a dental technology program.

“Government agencies use this information for funding allocations, and program planning. It’s also of value to human resources departments, job seekers, researchers, and others analyzing the workforce,” Curran explains. “We must petition to have the survey changed to include an educational category that reflects our industry’s present educational structure.”

However, the present educational structure is another area where Curran wants to see changes. “We need to establish linkages between workforce training and formal education standards to allow advanced placement,” she says. “If we can do that, our incumbent workforce could be upgraded to the single largest source of educated dental technicians in the world.”