Prior to this rule change, 16- and 17-year-olds could not be employed as dental assistants. The only clinical exposure they could gain was through an externship completed as part of a bona fide training program to meet course requirements — and if they turned 18 before graduating , they still could not be hired because L&I classified dental assisting as hazardous work due to bloodborne pathogen exposure, which was prohibited for minors. This changes on July 1.

New Registration Requirements for Minor Dental Assistants

Beginning July 1, 2026, DOH will allow 16- and 17-year-olds to apply for dental assistant registration if one of the following requirements has been met:

• The applicant is currently a student in a bona fide dental assistant career training or vocational education program; or
• The applicant has successfully completed a bona fide dental assistant career training or vocational education program.

DOH currently defines “bona fide” as a dental assistant education and training program offered at a school approved or licensed by one of the following:

• Washington Workforce Training and Education Coordinating Board;
• Washington Student Achievement Council;
• Washington State Board for Community and Technical Colleges; or
• Washington State Skill Centers certified by the Office of the Superintendent of Public Instruction.

Before beginning clinical dental assisting work, the individual must be registered as a dental assistant with the Department of Health (DOH). A pending application does not qualify.

DOH is already processing applications and will begin approving them ahead of the July 1 effective date, so eligible students are encouraged to submit their applications now.

Before You Hire: Additional Requirements for Minor Employees

In addition to the new DOH registration requirement, hiring a 16- or 17-year-old dental assistant involves existing child labor compliance obligations that apply to all minor employees in Washington. Dental practices should be prepared to meet the following requirements before a minor begins work:

• Minor work permit — Employers must have a minor work permit endorsement on their Washington business license before a minor begins work.
• Parent/school authorization — A completed Parent/School Authorization form must be on file at the worksite before the minor begins work.
• Hours restrictions — During the school year, 16- and 17-year-olds may work no more than 20 hours per week and no more than 4 hours on a school day. During school vacations, the limit increases to 48 hours per week and 8 hours per day. Minors cannot work during school hours unless a specific exemption applies.

Practices should review L&I's teen worker resources below for the full requirements, including scheduling restrictions and available variances.

Legislative Background

L&I adopted new youth employment rules implementing HB 1722, SHB 1121, and ESHB 1644. For dental practices, the key change is HB 1722, which allows minor dental assistants registered with DOH to work in clinical environments where bloodborne pathogens exposure is present.