The Ontario government is consulting on a proposal to grant dental hygienists and denturists the authority to order and perform diagnostic imaging, including dental X-rays. As part of broader legislation under Bill 56, the changes aim to let regulated health professionals work to the full extent of their training — a move that could reshape how dental care is delivered across the province.
As of May 2026, Ontario is actively reconsidering the scope of practice boundaries for several regulated health professions, and dental care is directly in the crosshairs. If the proposed changes move forward, dental hygienists would gain the authority to order X-rays independently, and denturists would be permitted to both order and operate X-ray machines. For practice owners, associates, and dental team members across Toronto and the Greater Toronto Area, these proposals deserve careful attention.
What the Ontario Government Is Proposing
The proposed scope of practice changes fall under Ontario's broader healthcare access initiative, Your Health: A Plan for Connected and Convenient Care. Bill 56, if passed, would extend diagnostic imaging authority to 16 additional regulated health professions — dental hygienists and denturists among them.
Specifically, the proposals would allow:
- Dental hygienists: Authority to order diagnostic imaging, including dental X-rays, as part of their independent assessment and treatment planning process.
- Denturists: Authority to both order X-rays and operate X-ray machines, enabling them to capture diagnostic images within their own practices without requiring a referral to a dental office.
The rationale from the Ontario government centres on reducing wait times, improving access to care in underserved communities, and allowing regulated professionals to practise at the top of their training. The Denturists Association of Ontario has publicly supported the proposal, noting that it would benefit patients through faster treatment and more comprehensive oral health care closer to home.
How the College of Dental Hygienists of Ontario (CDHO) Has Responded
The College of Dental Hygienists of Ontario (CDHO) has been actively involved in the consultation process. The CDHO has previously proposed enhancements to the scope of practice for registered dental hygienists in Ontario, including changes to the Healing Arts Radiation Protection Act (HARPA) that would permit dental hygienists to be designated as Radiation Protection Officers — enabling them to own and operate dental X-ray machines independently.
Additionally, the CDHO has advocated for dental hygienists to be permitted to prescribe and administer local anaesthetic by injection in the orofacial complex, further expanding the range of services dental hygienists could deliver without direct dentist supervision.
Pro Tip: If you employ dental hygienists in your practice, review the CDHO's current scope of practice documentation at cdho.org to understand which activities your hygienists can already perform independently. Many Ontario practices underutilize their hygienists' existing scope.
What This Means for Ontario Dental Practices
The potential impact on dental practices varies depending on practice structure and patient volume:
For Practice Owners and Associates
If dental hygienists gain imaging authority, it could affect referral patterns and revenue streams in practices that currently rely on imaging as part of comprehensive dental exams. However, it also creates opportunities. Practices with multiple hygienists operating in independent hygiene rooms could see improved throughput if hygienists can order and interpret preliminary imaging without waiting for a dentist to authorize the exposure.
In multi-location practices across the GTA — from Mississauga to Markham to Scarborough — this could meaningfully reduce patient wait times for hygiene appointments that include radiographic assessment.
For Dental Hygienists
Independent imaging authority would represent a significant expansion of professional autonomy. Dental hygienists already practise independently in some Ontario settings, including mobile dental hygiene services in long-term care facilities, community health clinics, and remote communities. However, the inability to order diagnostic imaging has been a persistent limitation in those independent settings. Removing that barrier could expand the scope of community-based dental hygiene services, particularly in areas without convenient access to a dental office.
For Denturists
The ability to order and perform X-rays within denturist practices could streamline treatment for patients requiring dentures, particularly when pre-treatment imaging is needed to assess bone density, retained roots, or other anatomical considerations that affect prosthetic planning.
The RCDSO Perspective
The Royal College of Dental Surgeons of Ontario (RCDSO), which regulates dentists and dental specialists in Ontario, has historically maintained that diagnostic imaging interpretation requires the training and clinical judgment of a dentist or dental specialist. As of May 2026, the RCDSO has not issued a formal public statement specifically addressing Bill 56's diagnostic imaging provisions for other oral health professionals.
Practice owners should monitor the RCDSO's communications channels for updated guidance, particularly regarding how collaborative care models between dentists and other oral health professionals should be structured if scope of practice boundaries shift.
Pro Tip: Regardless of how the legislation evolves, invest in cross-training your dental team on radiation safety protocols and the ALARA (As Low As Reasonably Achievable) principle. The Ontario Ministry of Health's HARPA requirements apply to all professionals who operate X-ray equipment, and compliance expectations will likely intensify as more professions gain imaging authority.
Broader Context: Scope Expansion Across Canada
Ontario is not acting in isolation. British Columbia, Alberta, and Saskatchewan have all moved toward expanded scope for dental hygienists in recent years. The Canadian Dental Hygienists Association (CDHA) has consistently advocated for dental hygienists across the country to practise to their full training capacity.
Meanwhile, the Canadian Dental Care Plan (CDCP) has added another dimension. As of April 1, 2026, dental hygienists can claim codes for periapical radiographs in series of 7 and 8 images under the CDCP fee schedule — a change that aligns the federal program with expanded provincial scope of practice trends.
For Ontario dental practices that serve CDCP patients — and with over 6.3 million Canadians now enrolled in the program — understanding how scope of practice changes intersect with federal billing frameworks is increasingly important for practice viability.
Timeline and Next Steps
Bill 56 is currently in the consultation phase, and timelines for legislative passage and regulatory implementation remain uncertain. Even if the bill passes in its current form, the CDHO and the College of Denturists of Ontario would need to update their respective regulations, practice standards, and quality assurance programs before practitioners could exercise expanded authorities.
Historically, significant scope of practice changes in Ontario health professions take 12 to 24 months from legislative passage to full implementation. Practice owners should use this window to assess their operational models, staffing structures, and technology infrastructure.
Frequently Asked Questions
Q: Can dental hygienists in Ontario currently order or take X-rays independently?
Dental hygienists in Ontario can currently expose dental radiographs under the supervision framework outlined by the CDHO and HARPA. However, they cannot independently order diagnostic imaging or serve as Radiation Protection Officers. The proposed changes under Bill 56 would expand these authorities, but the legislation has not yet been passed.
Q: How would this affect dental office staffing and workflow?
If dental hygienists gain independent imaging authority, practices could restructure workflows so that hygienists complete preliminary imaging assessments before the dentist enters the operatory. This could reduce patient chair time and improve scheduling efficiency, particularly in high-volume practices across Toronto and the GTA.
Q: Will denturists be able to take X-rays in their own clinics?
Under the proposed changes, denturists would gain authority to both order and operate X-ray equipment. However, they would still need to comply with HARPA requirements, including facility inspections, radiation safety training, and equipment standards. Implementation timelines depend on Bill 56 passing and the College of Denturists of Ontario updating its regulations.
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