I am social worker, the mother of 3 k-12 students and a 2015 k-12 graduate and the chair of a local school board. I have worked in the field of developmental disabilities for more than 25 years, including serving as the president of the ARC of VA for 4 years in the late 90's.

I would like to take this opportunity to share with you my concerns about 8VAC20-750. I think the state must strongly consider the ramifications of a policy that outlines the ways in which adults can legally and forcibly control a student through the use of restraint and/or seclusion.

First, let me say, that best practice in crisis management and intervention has come a long way from restraint and seclusion. Trauma informed care and restraint and seclusion free policies are in place at the local level across the country. If the state of Va is not prepared to implement current best practice for crisis management, I would like the following to be considered. 

1) The use of prone restraints must be banned, as well as any restraint that impedes breathing.  These have resulted in student and detainee deaths across the nation. 

2) It must be clear that r/s should only be used in an emergency situation.  There can be no room for interpretation.  "To quell a disturbance or to maintain order and control, or  for insubordination" can be defined in multiple ways.  Using r/s should never be a judgement call.

Any time staff physically restrain or seclude a student there are huge risks for the students, staff and school divisions.

If the VADOE must maintain a r/s policy, my recommendation, is that within that policy there are requirements to train all teachers, administrators, staff, (to include bus drivers) on de-escalation techniques, trauma informed care, AND best practice in crisis management and intervention to include options for NO use of r/s. And most importantly, attached funding to the required  training.

Having worked in a VA state MR training center back in the 80's on a special behavior unit and having had experience restraining and secluding residents routinely and being part of a 3 man team that broke a young man's arm during a prone restraint with cuffs, I can tell you that tragedy haunts me to this day. VADOE r/s policy needs to keep students and staff safe recognizing the field has learned a lot since the 80's.  My fear is that current policy does not reflect that current best practice.