Unlicensed Dental Assistants

Unlicensed dental assistants are not licensed by the Dental Board of California (Board), but they are subject to certain laws governing their conduct. Section 1085 is the regulation governing the duties that unlicensed dental assistants are allowed to perform. Unless a specific duty is listed in that regulations, the dental assistant is NOT allowed to perform that duty. A dental assistant may only expose radiographs after successful completion of a board-approved radiation safety course. Dental assistants with certain experience or educational backgrounds may qualify to apply for Registered Dental Assistant (RDA) licensure.

Allowable Duties/Frequently Asked Questions

Law and regulation specifically define the duties that each category of RDA and Registered Dental Assistant in Extended Functions (RDAEF) is allowed to perform, the level of dentist supervision required, and the settings in which the duties may be performed. It is a criminal offense to perform illegal functions, as well as grounds for license discipline of both the person performing the illegal function and any person who aid or abets such illegal activity.

The duties that RDAs are allowed to performed are specified in Section 1086 of the regulations.

Following are frequently asked questions about allowable duties:

  • May RDA's and RDAEF's bleach teeth?
    • Dental Board regulations were changed effective February 23, 2000, to allow RDAs, under direct supervision, to apply bleaching agents, and to activate bleaching agents with a non-laser light-curing device. Unlicensed dental assistants are not allowed to perform this duty.
  • Who may place fluoride varnishes?
    • A fluoride varnish is considered a non-toxic topical agent, and can therefore be placed by an unlicensed dental assistant as well as RDA's and RDAEF's.
  • Who may perform coronal polishing, and when? Is coronal polishing considered an oral prophylaxis?
    • An unlicensed dental assistant may not perform coronal polishing. Only a licensed RDA may perform coronal polishing, AFTER successful completion of a Board-approved course and submission of certification thereof to COMDA.
      A licensed dentist or registered dental hygienist must determine that the teeth to be polished are free of calculus or other extraneous material PRIOR to coronal polishing.
      Coronal polishing may not be intended or interpreted as a complete oral prophylaxis, which is a procedure which can be performed only by a licensed dentist or registered dental hygienist.
      An oral prophylaxis is defined in Regulation Section 1067(g) as:
      "Oral prophylaxis' means the preventive dental procedures including complete removal of explorer-detectable calculus, soft deposits, plaque, stains, and the smoothing of unattached tooth surfaces. The objective of this treatment shall be creation of an environment in which hard and soft tissues can be maintained in good health by the patient."
  • May a RDA or RDAEF administer anesthesia, or insert or remove IV lines?
    • No RDA or RDAEF may insert IV lines, administer anesthesia and medicines via the IV, and or remove IV lines, unless the person possesses another license (such as R.N. or L.V.N.) that allows them to perform such duties.
      While Regulation Section 1085 allows DA's to perform such basic supportive procedures as extra-oral duties, the "extra-oral" duties of inserting IV lines, administering anesthesia, or removing such lines do not meet the definition of a "basic supportive procedure", which is defined in Regulation Section 1067(l) as:
      "Basic supportive dental procedures' means fundamental duties or functions which may be performed by an unlicensed dental assistant under the supervision of a licensed dentist because of their technically elementary characteristics, complete reversibility and inability to precipitate potentially hazardous conditions for the patient being treated."

For specific questions not answered on this site, you can also contact us.