WSR 25-17-018
PROPOSED RULES
DEPARTMENT OF HEALTH
(Dental Quality Assurance Commission)
[Filed August 11, 2025, 11:08 a.m.]
Original Notice.
Preproposal statement of inquiry was filed as WSR 25-03-075.
Title of Rule and Other Identifying Information: Expanded function dental auxiliaries; licensure requirements. The dental quality assurance commission (commission) is proposing amendments to WAC 246-817-195 Licensure requirements for expanded function dental auxiliaries (EFDAs), to allow the training for amalgam restorations on actual clinical patients to be optional. The proposed rule allows amalgam restoration training on typodonts or on clinical patients.
Hearing Location(s): On October 24, 2025, at 10:00 a.m., at the Washington State Department of Health, TC2 Room 166, 111 Israel Road S.E., Tumwater, WA 98501-5414; or via Zoom at https://us02web.zoom.us/webinar/register/WN_YeOpI0h5S22mqhm9r08MmA. Please follow this link to register for the virtual hearing which will give you instructions to either join the meeting on a device or to call in to the meeting on the phone. After registering, you will receive a confirmation email containing information about joining the webinar.
Date of Intended Adoption: October 24, 2025.
Submit Written Comments to: Debbie Gardner, Program Manager, P.O. Box 47852, Olympia, WA 98504-7852, email dental@doh.wa.gov, https://fortress.wa.gov/doh/policyreview, beginning the date and time of this filing, by October 14, 2025, at 11:59 p.m.
Assistance for Persons with Disabilities: Contact Debbie Gardner, program manager, phone 360-236-4893, TTY 711, email dental@doh.wa.gov, by October 14, 2025.
Purpose of the Proposal and Its Anticipated Effects, Including Any Changes in Existing Rules: Current rules require EFDA students to complete training in placing and finishing amalgam restorations on both a typodont (a plastic model) and on clinical patients. The proposed rule allows the training to be on either type, rather than requiring both.
The commission has received feedback from various EFDA programs in Washington state pertaining to the challenges students face finding clinical patients for amalgam restorations due to a reduction of amalgam procedures in the community. Updating this rule could modernize the requirements and remove barriers for EFDAs pursuing licensure in Washington state.
Reasons Supporting Proposal: Rule making is necessary to modernize the educational requirements and remove barriers for EFDAs pursuing licensure in Washington state. The proposed rule amendments meet the intent of the underlying statutes by enforcing qualification for licensure and consistent standards of practice in WAC 246-817-195.
Rule is not necessitated by federal law, federal or state court decision.
Name of Proponent: Dental quality assurance commission, governmental.
Name of Agency Personnel Responsible for Drafting, Implementation, and Enforcement: Debbie Gardner, 111 Israel Road S.E., Tumwater, WA 98501, 360-236-4893.
A school district fiscal impact statement is not required under RCW
28A.305.135.
A cost-benefit analysis is required under RCW
34.05.328. A preliminary cost-benefit analysis may be obtained by contacting Debbie Gardner, P.O. Box 47852, Olympia, WA 98504-7852, phone 360-236-4893, TTY 711, email
dental@doh.wa.gov.
This rule proposal, or portions of the proposal, is exempt from requirements of the Regulatory Fairness Act because the proposal:
Explanation of exemptions: The entire proposed rule is exempt under RCW
19.85.025(4) as it only affects the dental license which does not meet the definition of "small business" in RCW
19.85.020.
Scope of exemption for rule proposal:
Is fully exempt.
August 7, 2025
Bryan Swanson, DDS, Chair
Dental Quality Assurance Commission
RDS-6364.1
AMENDATORY SECTION(Amending WSR 21-01-215, filed 12/23/20, effective 1/23/21)
WAC 246-817-195Licensure requirements for expanded function dental auxiliaries (EFDAs).
To be eligible for licensure as an EFDA in Washington an applicant must:
(1) Provide a completed application on forms provided by the secretary;
(2) Pay applicable fees as defined in WAC 246-817-99005;
(3) Provide evidence of:
(a) Completion of a dental assisting education program accredited by the Commission on Dental Accreditation (CODA); or
(b) Obtain the Dental Assisting National Board (DANB) certified dental assistant credential, earned through pathway II, which includes:
(i) A minimum of ((three thousand five hundred))3,500 hours of experience as a dental assistant within a continuous ((twenty-four through forty-eight))24 through 48-month period;
(ii) Employer-verified knowledge in areas as specified by DANB;
(iii) Passage of DANB certified dental assistant examination; and
(iv) An additional dental assisting review course, which may be provided online, in person or through self-study; or
(c) A Washington limited license to practice dental hygiene; or
(d) A Washington full dental hygiene license and completion of a course in taking final impressions affiliated with or provided by a CODA accredited dental assisting program, dental hygiene school or dental school.
(4) Except for applicants qualified under subsection (3)(d) of this section, provide evidence of completing an EFDA education program approved by the commission where training includes:
(a) In a didactic, clinical and laboratory model to the clinically competent level required for close supervision:
(i) In placing and finishing composite restorations on a typodont and on clinical patients; and
(ii) In placing and finishing amalgam restorations on a typodont ((and))or on clinical patients; and
(iii) In taking final impressions on a typodont; and
(b) In a didactic, clinical and laboratory model to the clinically competent level required for general supervision:
(i) In performing coronal polish, fluoride treatment, and sealants on a typodont and on clinical patients; and
(ii) In providing patient oral health instructions; and
(iii) In placing, exposing, processing, and mounting dental radiographs; and
(c) The basic curriculum shall require didactic, laboratory, and clinical competency for the following:
(i) Tooth morphology and anatomy;
(ii) Health and safety (current knowledge in dental materials, infection control, ergonomics, mercury safety, handling);
(iii) Placement and completion of an acceptable quality reproduction of restored tooth surfaces—Laboratory and clinic only;
(iv) Radiographs (covered in path II)—Laboratory and clinic only;
(v) Ethics and professional knowledge of law as it pertains to dentistry, dental hygiene, dental assisting, and EFDA;
(vi) Current practices in infection control;
(vii) Health history alerts;
(viii) Final impression;
(ix) Matrix and wedge;
(x) Rubber dam;
(xi) Acid etch and bonding;
(xii) Occlusion and bite registration;
(xiii) Temporary restorations;
(xiv) Dental emergencies;
(xv) Risk management and charting;
(xvi) Intra-oral anatomy;
(xvii) Pharmacology; and
(xviii) Bases, cements, liners and sealers.
(5) Except for applicants qualified under subsection (3)(d) of this section, attain a passing score on:
(a) A written restorations examination approved by the commission; and
(b) A clinical restorations examination approved by the commission.
(6) Provide any other information determined by the secretary.