1. ADD a regulation to BAN PRONE RESTRAINT. 
a. Keep the regulation forbidding any restraint that impedes breathing and specifically say that prone restraint is banned.
2. ELIMINATE the regulation allowing restraint and seclusion to be used to “maintain order & Control”
a. Restraint and seclusion should ONLY be used in self-defense or to defend others from serious physical harm- not when a child is being unruly or possibly showing a manifestation of their disabilities like not standing in line, exhibiting vocal tics, flapping their hands…etc.
3. REMOVE the regulation that lets schools seclude when investigating or questioning about violations of the student Code of Conduct.
a. Seclusion should only be in an emergency NOT become part of the investigation of violation of Code of Conduct. Seclusion is traumatic and dangerous.
4. Improve debriefing to require parental participation and have trained staff design appropriate programs to prevent future Restraint and Seclusion incidents. 
a. NOT part of the 15 Principals to turn this into child-blaming exercise.
5. CLARIFY that Restraint and Seclusion should only be used in conformity with the 15 Principles of the US Department of Education.
a. Cannot be used to “teach a child a lesson”.
6. CLARIFY that transportation personnel are EMPLOYEES that must comply with these Regulations 
a. Bus personnel wrongly use restraint on students that results in injury.