AB 873 defines what counts as an infection‑control course for dental assistants and creates a specific approval pathway and curriculum requirement for an eight‑hour course option that includes at least six hours of didactic instruction and two hours of laboratory instruction. The bill identifies acceptable delivery modes (including asynchronous and synchronous online learning and video laboratory demonstrations), enumerates required didactic topics and laboratory demonstrations tied to Cal/OSHA and the board’s Minimum Standards for Infection Control, and sets application, evaluation, and recordkeeping rules for course providers.
This matters to education providers, dental employers, and compliance officers because the statute both broadens allowable online delivery and tightens substantive and administrative standards: course directors must hold an active dental license, instructors must have Cal/OSHA instructional experience, providers must retain records for five years and submit to inspection, and certificates must state the board approval authority. AB 873 also clarifies that courses approved under the online/hybrid path do not satisfy infection‑control course requirements for RDA licensure or certain assistant permits, creating a discrete compliance regime for continuing education versus licensure pathways.
At a Glance
What It Does
Creates three acceptable forms of an eight‑hour infection control course (board‑approved program, Title 16 §1070.6 approval, or a board‑approved 6‑hour didactic/2‑hour lab course deliverable via video or online formats) and prescribes a detailed application and approval process for providers under the latter pathway. It mandates specific curriculum topics, laboratory demonstrations, evaluation criteria, instructor qualifications, record retention, and inspection rights for the Dental Board.
Who It Affects
Dental assisting education programs, independent continuing‑education providers, and dental offices that host or rely on infection‑control courses; the Dental Board of California and the Dental Hygiene Board for licensure oversight; vendors that supply instructional videos or online lab simulations. Students who enroll in these courses are affected by tech and sequencing requirements (didactic before lab).
Why It Matters
The bill standardizes content and delivery for infection‑control training while explicitly allowing online and video lab elements, balancing access and practical skills verification. It creates enforceable documentation and audit points that will change how providers design courses, how employers verify staff training, and how the Board monitors compliance.
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What This Bill Actually Does
AB 873 sets a clear definition for an infection‑control course: its primary purpose must be teaching infection‑control theory and clinical application to protect the public. For the eight‑hour option it authorizes a specific structured delivery: six hours of classroom‑style (didactic) instruction and at least two hours of laboratory instruction.
That laboratory time may be delivered through videos or a series of video training tools and can be synchronous, asynchronous, or a combination, but the statute requires hands‑on style demonstrations even when actual contamination is not used.
Providers who want board approval to offer the online/hybrid eight‑hour course must apply on a board form, pay the applicable fee, and submit detailed materials: course name/provider/director contact information; proof the course director holds a current license from the Dental Board or the Dental Hygiene Board; a written curriculum and objectives; objective evaluation criteria; and documentation that instructors have experience teaching relevant Cal/OSHA regulations and the board’s Minimum Standards. The bill lists specific didactic topics (from basic dental microbiology to sterilization, sharps management, waterline maintenance, and hazardous‑waste procedures) and requires corresponding laboratory demonstrations for each practical area.Operational and administrative rules follow the curriculum controls.
Providers must give prospective students advance notice of required technology, provide technical assistance, and ensure students complete didactic work before participating in laboratory demonstrations. The course must include a written exam tied to the curriculum that students must pass to receive a certificate.
The Dental Board may grant provisional approval for up to one year, reevaluate approved courses at least every seven years, inspect courses at any time, and withdraw approval for noncompliance. Providers must keep records — curricula, instructor credentials, and individual student records — for a minimum of five years and inform the board within 10 days of major course changes or closure.
Finally, certificates issued must state the statutory approval authority, and importantly, courses approved under this online/hybrid paragraph do not count toward infection‑control training required for RDA licensure or certain assistant permits.
The Five Things You Need to Know
The board-authorized eight‑hour course option must include at least six hours of didactic instruction and two hours of laboratory instruction, and lab hours may be delivered via video or online modalities.
Course directors must hold a current, active license from the Dental Board of California or the Dental Hygiene Board of California to qualify to run an approved course.
Instructors must demonstrate experience teaching Cal/OSHA regulations and the board’s Minimum Standards for Infection Control; the statute explicitly ties content to specific Cal/OSHA sections and Title 16 Section 1005 topics.
Providers must retain curricula, instructor credentials, student records, and related documentation for at least five years and notify the board within 10 days of major changes or closure.
A course approved under the online/hybrid (paragraph (3)) pathway cannot be used to satisfy the infection‑control course requirement for registered dental assistant licensure or for orthodontic assistant or dental sedation assistant permits.
Section-by-Section Breakdown
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Definition and three authorized eight‑hour course pathways
This subsection defines an infection‑control course by purpose (public protection through theory and clinical application) and then lists three ways an eight‑hour course may comply: a board‑approved program from an approved education program, an eight‑hour course approved under Title 16 §1070.6, or a board‑approved eight‑hour course with six didactic and two laboratory hours that can be delivered by video/online methods. Practically, this creates a specific approval track for hybrid/online providers while leaving existing board‑approved program routes intact.
Application packet and course director license requirement
Providers seeking approval for the online/hybrid option must submit a board form, pay the fee in Section 1725, and provide contact information and documentation. A key gatekeeper is the course director: the bill requires the director to hold an active dental or dental hygiene license, which limits who can qualify to administer courses and places professional accountability on a licensed clinician.
Curriculum, objectives, and instructor qualifications
The bill requires a written course outline that states curriculum, hours, and specific instructional objectives; objective evaluation criteria for student progress; and proof that instructors have experience instructing Cal/OSHA rules and the board’s Minimum Standards. The statute enumerates didactic content areas — from microbiology and modes of transmission to sterilization, hazardous chemicals, waterline maintenance, and waste management — so providers must map their lessons directly to those topics for approval.
Laboratory demonstrations, written protocols, and examination requirements
Providers must document laboratory instruction through defined demonstrations (hand‑cleansing technique, PPE donning/doffing, simulated contamination handling, sterilization processes, surface disinfection, sharps handling, lab device protocols, waterline testing, and regulated waste disposal). The course must include written laboratory protocols compliant with Title 16 §1005 and federal/state/local rules. The statute also requires a written exam that reflects the curriculum and must be passed before issuing a completion certificate, which places a clear assessment gate between training and certification.
Approval mechanics, provisional approval, reevaluation, and withdrawal
The board may approve, provisionally approve for up to one year, or deny course approval; it must provide written reasons for provisional approval or denial within 90 days. Approved courses are subject to reevaluation at least every seven years and may be inspected at any time; the board can withdraw approval if a course no longer meets statutory standards. These provisions give the Board both discretionary oversight and periodic automatic review triggers to maintain program quality.
Provider operational duties, records, student tech requirements, and certification limits
The course director must maintain records for at least five years, ensure instructor compliance, and notify the board within 10 days of major changes. Providers must inform prospective students about required computer/communications technology, provide technical assistance, and ensure didactic completion before lab participation. Upon passing the exam, students receive a certificate that specifies the statutory authority and identifies the approved provider. The statute also bars use of the paragraph (3) course to satisfy infection‑control requirements for RDA licensure or for certain assistant permits, drawing a line between continuing‑education formats and licensure‑grade training.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Patients and the public — benefit from a standardized, enumerated infection‑control curriculum and mandatory practical demonstrations tied to Cal/OSHA and board standards, which aim to reduce clinic infection risks.
- Dental assistants and students — gain clearer, uniform training requirements and an approved certificate format that documents subject‑matter coverage and assessment completion.
- Education providers that already meet these standards — they obtain a competitive advantage and a clearer path to board approval for online/hybrid offerings, including explicit permission to use video laboratory demonstrations.
- Dental offices and employers — receive more consistent documentation and subject‑level assurance when hiring or verifying staff training, simplifying compliance checks and internal audits.
Who Bears the Cost
- Small or independent continuing‑education providers — must upgrade curricula, hire licensed course directors or partner with licensed clinicians, secure instructor Cal/OSHA expertise, and invest in compliant laboratory demonstration materials and technology.
- Solo or small dental practices that currently run informal in‑house training — may need to change internal training to meet the statute’s documentation, sequencing (didactic before lab), and exam requirements or pay for externally approved courses.
- The Dental Board of California — takes on a heavier administrative load: reviewing applications, issuing provisional approvals, conducting inspections, and monitoring seven‑year reevaluations without explicit funding in the text.
- Students in low‑resource or rural areas — may face higher costs or access barriers if local providers cannot meet the new approval standards and must rely on approved providers with tech and lab capabilities.
Key Issues
The Core Tension
The core tension is between widening access through online and video‑based laboratory instruction and preserving meaningful, verifiable hands‑on competence: the bill authorizes flexible delivery but mandates practical demonstrations and stringent instructor qualifications, shifting the burden onto regulators and providers to reconcile convenience with clinical safety.
The bill tries to thread a needle: it expands permissible online and video delivery while insisting on laboratory demonstrations and instructor experience in Cal/OSHA and the board’s Minimum Standards. That hybrid approach raises immediate implementation questions.
How the Board will evaluate the adequacy of video‑based laboratory demonstrations versus live hands‑on practice is left to regulation and the approval process; the statute requires demonstrations "without actual contamination," but gives no objective competency benchmarks beyond a written exam and the instructor experience requirement. Regulators and providers will need to align on what constitutes satisfactory psychomotor skill verification in a remote or simulated environment.
Administrative friction is another risk. The statute assigns multiple documentation, notification, and inspection duties to providers and creates a multi‑step approval regime (including provisional approvals and seven‑year reevaluations).
For the Board, that means a steady stream of applications and compliance monitoring; the bill does not specify funding or staffing for that workload. For small providers, the licensing requirement for course directors and the specificity of didactic and lab demonstrations may force partnerships with licensed clinicians or shrink the pool of eligible providers, raising course costs.
Finally, drafting issues in the text (duplicated subparts and slightly inconsistent paragraph numbering) create potential ambiguity in enforcement. The prohibition on using the paragraph (3) course for RDA licensure and certain permits draws a bright line but also invites confusion over which infection‑control courses remain acceptable for licensure.
Regulations will need to clarify the interplay between this approval pathway and other board approvals or continuing education credits to avoid inconsistent outcomes across students and employers.
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