The practice of veterinary dentistry in California is governed by Section 4826 of the Business and Professions Code and Section 2037 of the California Code of Regulations. The laws are clear in stating that performing dentistry upon an animal is the practice of veterinary medicine and needs to be done under supervision of a licensed veterinarian.
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Section 4826, subdivision (d) of the Business and Professions Code, defines the practice of veterinary medicine to include the performance of a dental operation upon an animal. The definition of dental operation is contained in California Code of Regulations, title 16, section 2037:

  1. The application or use of any instrument or device to any portion of an animal’s tooth, gum or any related tissue for the prevention, cure or relief of any wound, fracture, injury or disease of an animal’s tooth, gum or related tissue; and
  2. Preventive dental procedures including, but not limited to, the removal of calculus, soft deposits, plaque, stains or the smoothing, filing or polishing of tooth surfaces.
  3. Nothing in this regulation shall prohibit, however, any person from utilizing cotton swabs, gauze, dental floss, dentifrice, toothbrushes or similar items to clean an animal’s teeth.

Subsection (3) of California Code of Regulations, title 16, section 2037, makes it clear that the only items that an unsupervised, unlicensed person may use to clean an animal’s teeth are “cotton swabs, gauze, dental floss, dentifrice, toothbrushes or similar items.” In a precedent decision adopted by the board in 2005, an Administrative Law Judge stated that a dental scaler is not at all similar to the soft items listed in the regulation, but is a curved pick with a sharp point. [1]  The Board supports the position that a dental scaler is not at all similar to any item on that list; therefore, the use of a dental scaler by an unlicensed or unregistered person not under supervision of a California licensed veterinarian is unlicensed activity. [2] In other words, “the use of a scaler by an unlicensed person is not illegal IF it is done under the supervision of a California licensed veterinarian.”[3]
In regards to tooth extraction, a RVT may perform dental extraction procedures “only under the direct supervision of a licensed veterinarian.”[4] However, an unregistered assistant can never perform dental extractions, regardless of supervision.[5]
 


[1] 2012 OAL Determination No. 4(S), <https://www.vmb.ca.gov/laws_regs/pd_2005-01.pdf>; Precedent Decision 2005-01, effective October 20, 2005, <https://www.vmb.ca.gov/laws_regs/pd_2005-01.pdf>.
[2] Ibid.
[3] https://www.vmb.ca.gov/about_us/agenda_items/vmbagenda_20120424_12.a.v.1.pdf
[4] Cal. Code Regs., Title 16, § 2036 (Animal Health Care Tasks for R.V.T.)
[5] Id. § 2036.5(a) (Animal Hospital Health Care Tasks for Unregistered Assistants).