One fact dominates this page. Washington's noncompetition statute, RCW chapter 49.62, contains a version of its central section that takes effect June 30, 2027 and states that beginning on that date all noncompetition covenants are void and unenforceable regardless of when the parties entered into them. If you are an associate under a restrictive covenant in Washington, or an owner who has been relying on one, that provision matters more than everything else here combined.
Key takeaways
- RCW 49.62 currently voids a noncompetition covenant unless the employee earns more than $100,000 a year (inflation adjusted), or $250,000 for an independent contractor. A duration beyond 18 months is presumed unreasonable.
- The version of RCW 49.62.020 effective June 30, 2027 states that beginning on that date all noncompetition covenants are void and unenforceable regardless of when they were entered into.
- Dentist CE is 63 hours every three years, including a one-time 3 hour suicide prevention course, 2 hours of health equity per cycle and a 1 hour online jurisprudence exam. Online self-study earns only 30 minutes of credit per hour completed.
- X-ray machines register through the state Business Licensing Service. The fee schedule sets a $245 annual facility registration fee plus annual per-tube fees, and dental facilities are inspected roughly every three to four years.
Rules change. Everything below was checked against an official Washington or federal source in September 2026. The 2027 noncompetition provisions are law but are not yet in force, and provisions of this kind are sometimes amended before their effective date. Confirm the current statute and talk to a Washington employment attorney before you act on it.
Who regulates what
| Topic | Agency | Official link |
|---|---|---|
| Dentist licensure and renewal | Washington State Department of Health, Dental Quality Assurance Commission | Dentist licensing information |
| Dentist continuing education | Washington DOH | Dentist continuing education |
| Dentist rules | WAC chapter 246-817 | WAC 246-817-440, continuing education |
| X-ray equipment registration | Washington DOH Office of Radiation Protection, via the Business Licensing Service | Registration of x-ray equipment |
| X-ray registration fees | WAC 246-254-053 | Radiation machine fee schedule |
| X-ray inspections | Washington DOH X-Ray Program | X-ray inspections |
| Non-competes | RCW chapter 49.62 | RCW 49.62, noncompetition covenants |
| Amalgam separators and dental wastewater | US EPA rule, enforced through your pretreatment control authority | EPA Dental Effluent Guidelines |
| Business licensing and sales tax | Washington Department of Revenue | Washington DOR |
License renewal and continuing education
Washington renews dentist licenses annually but verifies CE on a three year cycle tied to your renewal date. The total is 63 hours per three year period, and the composition is specific.
- Suicide prevention: a one-time three hour training, which counts toward the 63.
- Health equity: 2 hours every three years.
- Jurisprudence: a 1 hour requirement every three years, satisfied by a free online open book exam.
- Infection control: one hour on current standards, plus an annual review of your office's infection control policy.
- BLS: current healthcare provider basic life support certification, maintained annually.
The format rules are where Washington is harsher than most states. Online self-study earns only 30 minutes of credit per hour completed, so 30 hours of self-study yields 15 credits. Live webinars earn full credit, and so do recorded interactive webinars. Volunteer services are capped at 21 hours per three year cycle. There is no carryover of excess hours into the next period, and you are expected to retain your records for four years.
The half-credit rule on self-study is the single most expensive misunderstanding in Washington CE. If your plan is to close a gap with a discounted online bundle, double the hours you think you need, or find a live webinar instead. The difference is not a rounding error.
X-ray equipment: registration, fees and inspection
Registration in Washington runs through the state's Business Licensing Service rather than a standalone radiation portal, which is an administrative quirk that sends people to the wrong agency. The Office of Radiation Protection at DOH runs the program; the Department of Revenue runs the licensing system it is attached to.
The fee schedule in WAC 246-254-053 is structured as a facility fee plus per-tube fees, assessed annually:
- $245 annual radiation machine facility registration fee.
- Per-tube annual fees by category. Dental categories in the schedule include dental intraoral, dental handheld, dental panoramic and cephalometric, dental cone beam CT and dental educational, listed at $73. The schedule contains more than one dental line item, so read it against your own equipment rather than assuming a single number.
On inspections, DOH publishes frequencies by facility type: medical offices, clinics, hospitals and chiropractors every two years, mammography annually, and other facilities including dental, podiatry, veterinary and industrial every three to four years. The program says it oversees more than 6,500 facilities, which explains the interval.
What inspectors look at is published too: darkrooms and film processing, machine performance, image quality, technologist qualifications, operator protection, and patient exposure. The last item is described as the most important, which is a useful signal about where to spend your own attention between visits.
DOH also requires shielding plan review for new, remodeled or relocated medical x-ray facilities under WAC 246-225. The registration page does not state clearly whether dental facilities fall inside that requirement, so ask the program directly before a buildout rather than assuming either way. For the general mechanics, see dental x-ray registration and inspections and the equipment pages on intraoral x-ray units, panoramic units and CBCT units.
Buying and selling used equipment in Washington
Count tubes, not rooms
Because the fee schedule is a facility fee plus per-tube fees, the annual cost of an imaging fleet scales with the number of tubes. A practice with six intraoral tubes, a pan and a CBCT is paying the $245 facility fee plus eight tube fees, not one. Put that in the operating budget before you add operatories. Our operatory cost breakdown covers what else belongs in that number.
Registration, changes and disposal
Adding, removing or relocating a machine changes what should be on file. Washington's registration page links separate guidance on disposing of x-ray equipment, which is the page to read before you scrap a tube head rather than after. In a practice sale, ask the seller for the registration record and reconcile it against the machines physically in the building. A registration that lists equipment nobody can find, or a room with a unit that appears nowhere, is a reliable indicator of how the rest of the compliance file was kept.
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 discharging scrap amalgam, and restrictions on certain line cleaners), and you file a one-time compliance report with your pretreatment control authority. EPA routes those reports to a state agency in only a handful of states, and Washington is not one of them, so your control authority is almost certainly your local sewer utility. Ask what they expect from an incoming owner at closing. See amalgam separators.
Lead, chemicals and processor rooms
Lead foil, lead aprons, spent fixer and developer and lead-lined cabinetry need a licensed waste vendor and manifests. See dental waste disposal and disconnecting dental equipment safely. Before you commit, run the pre-purchase equipment checklist and read the hidden costs of buying used equipment.
Non-competes and employment
The rules in force today
RCW chapter 49.62 has governed Washington noncompetition covenants since 2019. The version in force until June 30, 2027 provides that:
- A noncompetition covenant with an employee is void unless the employee's earnings exceed $100,000 a year, a figure adjusted annually for inflation.
- For an independent contractor, the threshold is $250,000, also inflation adjusted.
- A duration longer than 18 months after termination is presumed unreasonable, and the party seeking to enforce must rebut that presumption with clear and convincing evidence.
- Terms must be disclosed in writing no later than the time the employee accepts the offer, and independent consideration is required if the covenant is added after employment begins.
- A 2024 amendment added protections tied to layoffs, requiring compensation during an enforcement period for a terminated employee.
- Covenants connected to the sale of a business remain enforceable where a party acquires or disposes of at least a one percent ownership interest.
In a dental office, the thresholds sort people cleanly. Most associate dentists clear $100,000 and are therefore subject to a covenant that meets the other requirements. Hygienists, assistants and administrative staff often will not, which makes restrictive language in their offer letters void on its face today.
What changes on June 30, 2027
RCW 49.62 now contains a parallel set of sections that take effect June 30, 2027, including a replacement for the "when void and unenforceable" section. That version states that beginning on June 30, 2027, all noncompetition covenants are void and unenforceable regardless of when the parties entered into the covenant.
Read that sentence carefully, because the "regardless of when the parties entered into" language is what makes it unusual. Most statutory changes apply prospectively to new agreements. This one is written to reach covenants already signed. If it takes effect as written, the non-compete in an associate contract signed in 2021 is as void as one signed next week.
Two things do not disappear. The 2027 section headings in the chapter separate out nonsolicitation agreements, which are treated differently from noncompetition covenants, and the chapter continues to address franchisor restrictions and an employee's right to hold an additional job. So the practical drafting question in Washington is shifting from "how wide and how long" to "what can a patient and staff nonsolicitation clause legitimately do."
If you are an owner, this is a planning problem rather than an emergency: your protection has to come from nonsolicitation terms that survive, from confidentiality and trade secret provisions, and from the economics of the relationship rather than from a geographic radius. If you are an associate, do not treat a covenant as unenforceable on your own reading. Get a Washington employment attorney to confirm how the effective date applies to your specific agreement before you act on it.
At the federal level, the FTC's non-compete rule is not in effect. The Commission announced on September 5, 2025 that it would dismiss its appeals and accede to the vacatur of the rule, so state law controls. See our national overview of non-compete agreements for dentists, the associate contract red flags guide, and the contract review checklist.
What we could not confirm
- The current inflation-adjusted earnings thresholds under RCW 49.62 for this year. The statute provides for annual adjustment; the adjusted figures are published separately.
- Which dental fee line applies to a given machine in WAC 246-254-053. The schedule contains more than one dental entry and we did not resolve which applies to which configuration.
- Whether shielding plan review under WAC 246-225 applies to dental facilities, or only to medical ones. The registration page is ambiguous.
- Dental hygienist and dental assistant CE requirements in Washington. Confirm from the Department of Health pages for those professions.
- Whether the June 30, 2027 provisions will be amended before they take effect, and how courts will apply the retroactive language.
- Sales and use tax treatment of dental equipment, including private party purchases. Confirm with the Department of Revenue and your CPA.
Where to verify
- Washington Department of Health: dentist licensing and dentist continuing education
- Washington DOH X-Ray Program: equipment registration and inspections
- Washington State Legislature: WAC 246-254-053, radiation machine fees, WAC 246-817-440, dentist CE, and RCW chapter 49.62, noncompetition covenants
- US Environmental Protection Agency: dental effluent guidelines, 40 CFR Part 441
- Federal Trade Commission: September 2025 statement on the non-compete rule
- Washington Department of Revenue: dor.wa.gov
Putting it to work
Owners should be rewriting Washington employment templates now rather than in 2027, shifting the protective weight onto patient and staff nonsolicitation terms, confidentiality, and a compensation structure that makes staying attractive. Associates should read their own covenant against both the current earnings threshold and the 2027 provision, with counsel, before making any move. On the equipment side, count your tubes, check your fee line, and calendar the three to four year inspection window so it does not arrive unannounced.
Related reading: non-compete agreements for dentists, x-ray registration and inspections, the compliance chapter of the operations guide, 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.