Florida Statutes, sections 466.021 and 466.032, were amended. The changes took effect in January, 2009.
The new law requires dental laboratories “not physically located within a dental practice operated by a dentist” to complete 18 hours of continuing education credit before July 1, 2010. In other words, if this is your in-house lab, you DO NOT need to attain the continuing education hours. This was due to the FDA’s intervention in the legislative process. But, as is likely the case, you don’t have your own lab and rely on commercial labs— and those labs are registered in Florida— then they will need to comply with the CE requirement before their next registration cycle (July 1, 2010).
Note that the CE requirement DOES NOT apply to commercial labs located in another state or country, because Florida law applies only to Floridaregistered labs. The point for dentists to remember is that, after July 1, 2010, you DO NOT want to do business with a Florida-registered lab that has failed to get its CE hours. Also, if you use a Florida-registered dental lab, you must now include:
- • Your dental license number on what was formerly known as the “work order,” now called a “prescription;” and
- • A “specification of materials to be contained in each work product”.
When the Florida lab delivers the final product to you, verify that you also receive written disclosure of:
- • All materials used by the lab in manufacturing the appliance;
- • Certificates of authenticity for each product manufactured; and
- • The point of origin of manufacture of each restoration, including the address and contact information of the dental lab.
Please work with your lab to make sure you get the written disclosures. Once you do, treat them with the same dignity as you would other patient records. Keep the disclosure form on file or with your patient’s chart.
DO NOT throw it away as “packing material.” Thanks to the efforts of the FDA, we are happy to report that the continuing education mandate and the point of origin disclosure DO NOT apply to your in-house labs. In other words, if you employ a dental laboratory technician who works in your office, under your supervision, and only for you; then neither you (nor your lab tech) need concern yourselves about these new laws that took effect January 1, 2009.
The FDA has also helped to ensure that dentists may continue to do business with out-of-state labs if they wish.
The legislation contains language stating that the new requirements DO NOT apply to dental laboratories in another state (e.g., Georgia or Alabama) or country (e.g, China or India).