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DOH Releases Draft Report on Denturist Scope Expansion

The Department of Health (DOH) has released the draft of its Denturist Scope of Practice Sunrise Review on expanding the scope of practice of licensed denturists to include “making, placing, constructing, altering, reproducing, or repairing all other nonorthodontic removable oral devices” and “teeth whitening using bleaching solutions of twenty percent or less." A complete copy of the DOH report can be found here. In the draft proposal, DOH recommends that this language NOT be adopted into law. Here is DOH’s rationale:

The department finds substantial risk of patient harm if the broad definition of “nonorthodontic removable devices” proposed in House Bill 2815 is adopted:

Rationale: Allowing the broad use of “nonorthodontic removable oral devices” opens up the scope of practice for denturists to work with obstructive sleep apnea (OSA), which requires specialized training, even for fitting and follow up for the devices. If not properly diagnosed and treated, OSA can lead to cardiac disease, hypertension, and stroke. In addition, the devices can lead to adverse effects such as dental crown damage, tooth, mouth, and jaw damage, skeletal changes, and Temporomandibular Joint Disorder (TMJ).

The DOH opinion is consistent arguments made by WSDA and the Dental Quality Assurance Commission (DQAC). WSDA’s comments can be found here and DQAC’s comments can be found here.

Though DOH did not support adoption of this specific denturist expansion language, DOH has provided more limited legislative language that could be used by the Legislature to expand denturist scope of practice. These recommendations are as follows:

The following services could possibly be added to the denturist scope of practice if additional safeguards and assurances are included:

1. Allow denturists to fabricate and fit bruxism (grinding and clenching of teeth) devices and sports mouthguards only if:

  • The definition of “nonorthodontic removable oral devices” is narrowed to only bruxism devices and sports mouthguards.
  • Training requirements are set in law or required in rule to ensure currently licensed denturists have the necessary skill to create and fit these devices.
  • Language is added for bruxism devices to require a consultation with a dentist to ensure there is no temporomandibular disorder (TMJ) present before a denturist proceeds with fabrication of the device.
  • Written instructions are provided to the patient encouraging regular dental checkups to identify any adverse effects of bruxism or from the device.

Rationale: These devices are not a high risk to the public as long as denturists have received appropriate training, consult with a dentist as needed, and encourage regular dental checkups.

2. Allow denturists to provide teeth whitening trays and over-the-counter solutions for the patient’s use at home if they also provide written instructions encouraging regular dental checkups.

Rationale: Opponents did not provide evidence that allowing denturists to provide this service would be a high risk to the public. Fabrication of the trays includes similar processes used in making dentures, such as taking impressions casts and vacuum forming the trays. Teeth-whitening trays do not move the teeth or jaw and the whitening gel is the same strength currently available over-the-counter.

3. Allow denturists to provide cosmetic appliances, such as the Snap-on-Smile, regardless of whether the patient is missing teeth.

Rationale: This is a patented cosmetic appliance that covers the teeth and is removable. It simply requires an impression of the teeth be sent to the manufacturer for fabrication, followed by a fitting. There does not appear to be a risk to the public, and this fits in with the work denturists already do.

WSDA is currently reviewing these DOH recommendations. Rebuttal comments on the draft report can be made until September 20 at 5:00 to

WSDA will provide updates on this process as they develop. Please address questions and comments to Bracken Killpack, Director of Government Affairs, at or 800-448-3368.

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