I am writing to express my support for the Coalition for the Improvement of School Safety (CISS) platform and to ask the Board to ensure that the proposed regulations are consistent with the Fifteen Principles, as required by law. Below are some recommendations. Instead of Restraint and Seclusion, schools should use proved applied behavior analysis techniques to address problem behaviors, to prevent behaviors from occurring in the first place. Our schools lack properly trained individuals and restraint/seclusion results in increase, not a decrease, in problem behaviors. 

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CISS Recommendation 1: The Board must keep the protection in the regulations to prohibit restraint and seclusion solely to prevent property damage.

CISS Recommendation 2: The Board must keep the requirement in the regulations for schools to make reasonable efforts to provide same-day notification to parents when seclusion and restraint are used and to provide written reports of restraint and seclusion incidents.

CISS Recommendation 3: The Board must add an explicit prohibition on prone restraint. This form of restraint is extremely dangerous and is prohibited by the Fifteen Principles. The recommendations cannot be consistent with the Fifteen Principles and comply with Virginia law unless they contain an explicit ban on prone restraint.

CISS Recommendation 4: The Board must omit the carve-out for seclusion of students during the investigation of alleged code of conduct violations. Placing a child in a room they believe they are not free to leave is seclusion, and it is dangerous. This loophole in the regulation would allow schools to seclude students for behavior as minor as possessing a cell phone or lying, and it must be closed.

CISS Recommendation 5: The regulations must clarify that restraint and seclusion may be used ONLY when necessary because of an “imminent threat of serious physical harm to self or others.”

CISS Recommendation 6: The Board must eliminate the exclusion of “incidental, minor, or reasonable physical contact or other actions designed to maintain order and control” from the purview of the regulations. This language is subject to broad interpretation and could result in undocumented and unregulated restraints occurring under the guise of “reasonable physical contact or other actions designed to maintain order and control.”