I reached-out to Bennett this morning for clarification. Here's his article that was published awhile back.
Header: Facts vs. Fiction – DOL Classification of Dental Laboratory Technicians
By NADL Chief Staff Executive Bennett Napier, CAE
This general timeline of activities, covering key moments in the last ten years, is intended to provide clarity on the classification system of occupations used by the U.S. Department of Labor (DOL), including dental laboratory technicians. The DOL has never used a “skilled vs. unskilled” classification system. That unfortunately, has been misinformation circulating for a number of years.
For background, the O*Net system classifies occupations based on the following criteria:
· how much education people need to do the work,
· how much related experience people need to do the work, and
· how much on-the-job training people need to do the work.
2010 - The U.S. DOL adopts a new Standard Occupational Classification (SOC) System. All occupations are classified within five “Job Zones.” The occupation of Dental Laboratory Technician (NAICS Code 51-9081) is placed in Job Zone 2.
May 2011 - NADL partners with ADA and a coalition of allied dental associations and corresponds with DOL proposing changes to the occupation classification for Dental Laboratory Technicians (DLTs).
June 2013 - NADL partners with ADA and a coalition of eleven other organized dental associations to send a formal letter to the DOL requesting that DLTs be classified in a higher Job Zone that more accurately describes the educational and training requirements to be proficient in the profession.
Fall 2013 – Summer 2014 - The U.S. DOL conducts a nationwide occupational survey to survey incumbent employees in the DLT occupation.
February 2014 - NADL works directly with the staff at the U.S. DOL on the survey analysis outcomes relative to levels of post-secondary formal education held by DLTs.
April 2014 - In response to NADL’S February communication, the U.S. DOL’s O*NET OnLine education categories are updated to show an additional category of education indicating that 27 percent of DLTs hold post-secondary education certificates or their equivalent according to the 2010 O*NET survey data.
One of the challenges that the dental laboratory technician profession faces in getting changed from a Job Zone 2 classification is the fact that Zone 3, 4, and 5 occupations require a post-secondary degree or certification and/or training. Further, many of the Job Zone 3 occupations or higher also require a state occupational license in order to work. None of those criteria/requirements exists except in a handful of U.S. states where a CDT or continuing education requirement may be required.
This element of fact with the DOL occupational classification is one of the many reasons NADL has invested a lot of time and money to help individual states seek to incorporate dental laboratory registration and/or a CDT or CE requirement in state dental practice acts. To have a larger number of states achieve this public policy objective would help in moving DLT from Job Zone 2 to at least Job Zone 3. This public policy outcome would also likely lead to survival of existing DLT educational schools, and facilitate the need for more schools to be developed.
Bennett Napier, M.S., CAE