Dental Board Votes to Clarify Registered Dental Hygienist Application Requirements


By Dimitri A. Davis

During its November 18, 2022, meeting [Agenda Item 24], the Dental Board of California (DBC) voted to include in the next Sunset Review Report a recommendation to amend Business and Professions Code sections 1752.1, 1752.4, and 1907 and repeal section 1752.6 Related to Registered Dental Hygienist Application Requirements.

Under current statute, a Registered Dental Hygienist (RDH) can perform the duties of a Registered Dental Assistant (RDA), and would be able to qualify for, and receive an RDA license before the performance of those duties.

DBC has identified language it considers redundant or confusing and is seeking, through a legislative proposal, to clarify the language and make it simpler for interested RDHs to apply for licensure as RDAs.

An increased number of RDHs have been applying for RDA licensure but some confusion surrounds the licensure requirements. The Board’s proposals intend to clarify the language of these specific application requirements. The three primary goals are to eliminate the redundant licensure requirements, to clarify the requirements for RDA additional duties requirements, and to clarify requirements for licensure of RDHs as RDAs.

DBC proposed adding to Business and Professions Code section 1752.1 a new paragraph set to subdivision A explaining that a licensed RDH could meet the requirements for RDA licensure by submitting an application to the Board and through satisfactory performance on the RDH combined written and law and ethics examination. This would reduce RDH licensure redundancy so the licensed RDA would not have to retake certain courses required for RDA licensure that RDHs already have to take.

DBC also proposed amending Business and Professions Code section 1752.4 subdivision B to remove certain gender identifying language and to restructure the sentence for improved clarity. DBC also proposed removing the requirement in subdivision B for RDA submission to the Board evidence of completion of courses in additional duties, and clarifying in subdivision C that the supervising dentist has the responsibility to ensure the RDH has completed required courses in order to perform those additional duties.

DBC proposed repealing Business and Professions Code section 1752.6, calling it “outdated” and “no longer needed.” DBC stated these amendments would make the statute consistent with the broader movement within California toward gender neutral language, improved efficiencies in DBC’s board licensing process, and reduced costs in issuing licenses for Registered Dental Assistants.

DBC also proposed amending Business and Professions Code section 1907 to clarify that an RDH licensee shall apply for, and receive, a license as an RDA in accordance with section 1752.1 subdivision A(4), and to complete any additional education required by the state by section 1752.4 subdivision P(b), prior to performance of the Registered Dental Assistant duties.


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