Florida is a high-volume state with a well-organized regulator and an unusually long x-ray inspection cycle. The Department of Health registers more than 64,000 x-ray machines and inspects dental and podiatry facilities every five years. That long interval is a trap for used equipment buyers: a machine can be five years past its last look, and the report you are relying on may predate the last two owners.
Key takeaways
- The Florida dental licensing biennium runs March 1 through February 28 of even-numbered years. An initial license expires February 28 of the following even-numbered year.
- Board rule 64B5-12.013 sets continuing education at 30 hours per biennium for dentists and 24 for dental hygienists, with a CPR course each biennium, a medical errors course, a domestic violence course, and an HIV and AIDS course required no later than the first renewal.
- Dental and podiatry x-ray facilities are inspected every five years. When deficiencies are identified, owners have 90 days to correct them, and a machine posing an immediate threat must come out of service immediately.
- A dental assistant who positions and exposes radiographs needs a dental radiographer certification from the Board of Dentistry, which requires at least three months of continuous on-the-job training plus a Board-approved radiography course completed within 12 months of that training.
Rules change. Everything below was verified against an official Florida or federal source in September 2026. The CE figures come from the text of rule 64B5-12.013 as published through the Florida Administrative Rules system, and the version we read was a rule filing, so check the current codified rule before you buy CE. Confirm everything with the board or department before acting.
Who regulates what
| Topic | Agency | Official link |
|---|---|---|
| Dentist and hygienist licensure and renewal | Florida Department of Health, Board of Dentistry | Florida Board of Dentistry licensing |
| Continuing education rules | Board of Dentistry, F.A.C. chapter 64B5-12 | F.A.C. 64B5-12, continuing professional education |
| Dental hygiene and dental assistant scope | Board of Dentistry, F.A.C. chapter 64B5-16 | Florida dentistry laws and rules |
| Radiographic operator requirements | Board of Dentistry (dental radiographer certification), rule 64B5-9.011 | Dental radiographer |
| X-ray machine registration | Florida Department of Health, Radiation Control | Ionizing radiation machines (x-ray) |
| Registration portal and annual fees | Florida Department of Health | Florida X-ray portal |
| Radiation rule text | F.A.C. chapter 64E-5, control of radiation hazard regulations | 64E-5.511, registration of radiation machines |
| Infection control in the dental office | Board of Dentistry (plus federal OSHA) | Florida Board of Dentistry |
| Amalgam separators and dental wastewater | US EPA rule, enforced through your local pretreatment control authority | EPA Dental Effluent Guidelines |
| Corporate practice and practice ownership | Board of Dentistry rules plus entity filings with the Florida Division of Corporations | Florida Board of Dentistry |
| Sales and use tax on equipment | Florida Department of Revenue | Florida Department of Revenue |
License renewal and continuing education
The board publishes the biennium clearly: the licensing biennium runs March 1 through February 28 of even-numbered years, and an initial license expires February 28 of the following even-numbered year. So a license issued in mid-2026 expires February 28, 2028.
The CE requirements sit in rule 64B5-12.013, and the version of the rule text we read through the Florida Administrative Rules system sets:
- Dentists: 30 hours per biennium.
- Dental hygienists: 24 hours per biennium.
- CPR: required during each license renewal biennium.
- Medical errors: a course covering root cause analysis, error reduction and prevention, and patient safety, with a minimum of 2 hours.
- Domestic violence: a 2 hour Board-approved course as part of every third biennial licensure renewal.
- HIV and AIDS: a Board-approved course pertinent to the practice of dentistry, required no later than upon first licensure renewal.
One caution. The domestic violence and HIV and AIDS requirements have both been amended in recent years, and the document we read was a rule filing rather than the codified rule. Confirm the current version on the Florida Administrative Rules site before you buy a course to satisfy one of them.
X-ray equipment: registration and inspection
The Florida Department of Health's radiation control program registers x-ray machines and runs the inspection program. The program's own figures give you a sense of scale: more than 64,000 registered machines and over 15,000 inspections a year.
What the department publishes:
- Registration of dental x-ray machines is required. Facilities register and pay annual fees through an online portal, using their registration number (the JR number) and facility zip code.
- Inspection frequency: mammography and cancer therapy annually, dental and podiatry every five years.
- When deficiencies are identified during an inspection, owners have 90 days to correct them. A machine posing an immediate threat must be removed from service immediately.
- Forms: DH Form 1107 for radiation machine registration, DH Form 1113 for vendor registration, DH Form 1114 for report of assembly of non-certified systems.
The five-year dental interval is the fact to build your internal habits around. Florida is not going to catch a drifting tube for you. Run your own quality assurance and keep your service records current, because you are the only one looking most of the time. Our equipment maintenance log is a reasonable place to keep it.
The JR number is the key to your registration record. Write it on the inside of your compliance binder and in your practice management notes. When you buy a practice, get the seller's JR number during due diligence so you can look up the registration and the last inspection date yourself.
Who may take radiographs
Florida requires a dental radiographer certification for a dental assistant to position and expose dental radiographs under indirect supervision of a licensed dentist. The requirements published by the board:
- At least three months of continuous on-the-job training in positioning and exposing dental radiographs under the direct supervision of a Florida licensed dentist.
- Successful completion of a Board-approved radiography course within 12 months of finishing that on-the-job training.
- Electronic fingerprinting through an FDLE-approved Livescan provider, a requirement added in 2024.
The governing rule is 64B5-9.011, and delegation of radiographic duties is addressed in 64B5-16.005(2)(i). The board notes that it does not issue licenses to dental assistants generally, it issues this certification.
The three-month training window matters for hiring. An assistant new to radiography cannot be certified on day one no matter how motivated they are, so plan coverage accordingly. For general background see dental x-ray registration and inspections.
Buying and selling used equipment in Florida
Registration and the five-year inspection gap
Registration with DOH is required for dental x-ray machines, and the department's online portal is where annual fees are handled. Update your registration when you add or remove machines so the state's inventory matches the building.
The bigger issue with used equipment in Florida is the inspection interval. A unit that passed its last state inspection four years ago has a state record that tells you almost nothing about its current condition. Do not treat a clean inspection report as a substitute for a real pre-purchase evaluation. Hire a service technician to test output, timer accuracy and mechanical condition. Our guide to equipment inspections before you buy and the inspection checklist cover what to look at.
The department does not publish a clear procedure for transferring or disposing of a registered machine on the pages we read, so call the radiation machines program directly when a unit leaves your building. The DH Form 1114 report of assembly is the form to know about when a non-certified system is assembled on site.
Amalgam separators and wastewater
The federal EPA dental rule at 40 CFR Part 441 applies. If you place or remove amalgam and discharge to a publicly owned treatment works, you need a compliant amalgam separator, you follow the best management practices (no flushing scrap amalgam, no oxidizing line cleaners), and you file a one-time compliance report with your pretreatment control authority, usually the county or city utility in Florida. Ask that utility what it expects from a new owner at closing, since EPA does not address transfers. See amalgam separators.
Lead, chemicals and decommissioning
Old darkrooms mean spent fixer and developer plus lead foil. Aprons fail. Lead-lined panels come out during remodels. Use a licensed vendor and keep the manifests. See dental waste disposal and disconnecting dental equipment safely. If you are the seller, start with pricing your equipment honestly.
Non-competes and employment
Florida is an enforcement-friendly state and has been for decades. Two statutes now sit in Chapter 542, and which one applies to you matters.
Section 542.335, the long-standing rule
Florida Statute 542.335 governs restrictive covenants generally. A court will not enforce a restrictive covenant unless it is set forth in a writing signed by the person against whom enforcement is sought. The party enforcing it must prove at least one legitimate business interest, and the statute lists five recognized categories: trade secrets, confidential business information that does not qualify as a trade secret, relationships with prospective or existing customers or clients, goodwill associated with a trade name, trademark, service mark, location or marketing area, and extraordinary or specialized training. A covenant not supported by any legitimate business interest is unlawful, void and unenforceable.
On duration, the statute sets rebuttable presumptions for restrictions against former employees, agents or independent contractors where no sale of a business is involved: a restraint of six months or less is presumed reasonable, and a restraint longer than two years is presumed unreasonable. Both presumptions can be overcome with evidence, which is why Florida litigation over these clauses is fact-heavy.
The CHOICE Act, and why it probably does not cover you
In 2025 Florida enacted the Florida Contracts Honoring Opportunity, Investment, Confidentiality, and Economic Growth Act, codified at sections 542.41 through 542.45. It creates two new, employer-favorable instruments: a covered garden leave agreement, where the employer keeps paying the worker through a notice period of up to four years, and a covered noncompete agreement of up to four years in a defined geographic area. The act carried a July 1, 2025 effective date under chapter 2025-213, and became law without the governor's signature, with an August 15, 2025 constitutional effective date.
The important detail for dentistry is in the definitions at section 542.43. A covered employee is an employee or individual contractor who earns or is reasonably expected to earn a salary greater than twice the annual mean wage of the relevant county, and the definition excludes health care practitioners. Read literally, that carve-out keeps dentists out of the CHOICE Act and leaves them under section 542.335.
Do not accept that reading from us. Confirm the exact definition and exclusion language in section 542.43 with a Florida employment attorney, and confirm how "health care practitioner" is defined for this purpose. The act is new, the courts have not worked through it, and a four-year covenant is a very different life than a two-year one.
At the federal level, the FTC's non-compete rule is not in effect. The Commission voted on September 5, 2025 to dismiss its appeals and accede to the vacatur of the rule, so Florida law governs. See non-compete agreements for dentists and the associate contract review checklist.
What we could not confirm
- Whether the CE figures and course requirements in 64B5-12.013 that we read from a rule filing match the currently codified rule. Check the Florida Administrative Rules site.
- Florida DOH procedures for transferring or disposing of a registered x-ray machine, and the annual registration fee amounts by machine count.
- Exactly how "health care practitioner" is defined for the CHOICE Act exclusion, and therefore whether any dental employment arrangement could fall inside the act.
- Whether Florida restricts non-dentist ownership of a dental practice, and to what extent. The board does not publish this clearly. Confirm with a dental-specific attorney.
- Sales and use tax treatment of dental equipment in Florida, including private-party purchases. Confirm with the Department of Revenue and your CPA.
Where to verify
- Florida Board of Dentistry: licensing, dental radiographer, and the dentistry laws and rules compilation
- Florida Administrative Rules: chapter 64B5-12, continuing professional education and 64E-5.511, registration of radiation machines
- Florida Department of Health: ionizing radiation machines and the x-ray registration portal
- Florida Senate: section 542.335, restrictive covenants, section 542.43, CHOICE Act definitions, and chapter 542 part II
- US Environmental Protection Agency: dental effluent guidelines, 40 CFR Part 441
- Federal Trade Commission: September 2025 statement on the non-compete rule
- Florida Department of Revenue: floridarevenue.com
Putting it to work
Two Florida habits. Because dental x-ray inspections come around only every five years, run your own annual quality assurance and keep service records, and never treat a state inspection report as a pre-purchase evaluation. And on the employment side, get the CHOICE Act question answered in writing by Florida counsel before you sign anything with a term longer than two years, because the answer decides whether you are looking at a presumptively unreasonable clause or a lawful four-year one.
Related reading: what to expect from an equipment inspection, x-ray registration and inspections, non-compete agreements for dentists, and the rest of the state resources directory.
This guide is educational content and does not constitute legal, financial, tax, or clinical advice. Laws and regulations vary by state and change over time. Consult your own dental-specific attorney, CPA, and state dental board before acting.