The National Fire Protection Association has had national standards on medical gas systems which are codified in the NFPA 99.  NFPA 99 has included dental offices performing any form of sedation, anesthesia, and anxiolysis since at least 1996. However, these rules have been seldomly enforced in dental offices.  In a discussion with members of the Virginia Society of Oral and Maxillofacial Surgeons, I was made aware that they have now made certification by an American Society of Sanitary Engineers (ASSE) 6030: medical gas verifier as part of their anesthesia self inspections for any new or rennovated gas system.  Given the unfortunate issues that have arisen in the past in Virginia, I would ask that the Board also consider these National Safety Standards when updating the sedation and anesthesia regulations.

In addition, the Dental Board has included by reference the American Academy of Pediatric Dentistry's (AAPD) Guidelines on Monitoring and Management of Pediatric Patients During and After Sedation for Diagnostic and Therapeutic Procedures.  However, there is no reference to AAPD Policy on the Use of Deep Sedation and General Anesthesia in the Pediatric Dental Office.  In this policy it states, "The pediatric dentist is also responsible for establishing a safe environment that complies with local, state, and federal rules and regulations, as well as the Guideline for Monitoring and Management of Pediatric Patients During and After Sedation for Diagnostic and Therapeutic Procedures for the protection of the patient."  The NFPA 99 is the ANSI (Federal) standard for medical gas systems. In addition it is also adopted by reference in the International Plumbing Code and International Fire Code, which are adopted by the Statewide Building Code (State).  Local enforcement of this has been variable, but the policy set forth by the AAPD and now by VSOMS suggests that the dentist is responsible for ensuring this step toward compliance is followed.

In addition, such great concern for patient safety in dentistry from lack of compliance with NFPA 99 exists, that the NFPA has included a new chapter in the 2018 revision of the NFPA 99 code.  This chapter, Chapter 15, is solely about dental offices.

I would ask that the Board consider these issues when changing the regulations on sedation and anesthesia.  They may not be currently enforced in dentistry, but with the new 2018 changes they certainly will be in the future. I am uncertain if this is something that the Board of Dentistry wishes to address at this time while comment is open on these regulations, or if this should be left to Building Inspectors and Fire Marshals. Nevertheless, I believe it prudent to consider.

Sincerely,

Jonathan L Wong, DMD, DADBA, DNDBA, FADSA *

Diplomate, American Dental Board of Anesthesia

Diplomate, National Dental Board of Anesthesia

Fellow, American Dental Society of Anesthesia

* The ADA does not recognize Dentist Anesthesiologists as specialists, therefore anesthesiology services are rendered as a general dentist with a general anesthesia permit.