Motivated by the constant modulus property of frequency shift keying (FSK) based waveforms and the stabilisation of its radar performance with an increase in the number of subpulses, in this paper an FSK-based dynamic subpulse number joint communications and radar waveform design is proposed. From a communications point of view, the system operates based on traditional FSK modulation. From a sensing point of view, although the subpulses are continuously generated and transmitted, radar waveforms are dynamically formed by monitoring the flatness of the spectrum which in turn guarantees the accuracy of the delay estimation. Other constraints on the waveform length are used to ensure satisfactory values of the root mean square time duration, ambiguity function sidelobe levels and prevent overly long waveforms. To provide an estimation of the probability of generating extremely long waveforms, the distribution of the number of subpulses is approximated using a Brownian motion process and an existing result on its one-sided exit density. Numerical examples are provided to evaluate the accuracy of the approximate distribution, as well as the ambiguity function sidelobe levels and the delay and Doppler shift estimation performance of the transmitted waveforms.