I am writing to oppose the proposed wording of the veterinary regulation listed below in italics.  While I understand the reasoning behind this proposal, implementation is impractical and at times may actually be detrimental to a patient (in times during an emergency when anesthesia is needed and an LVT is not available).  I feel the regulation should read: "When possible, a licensed technician should intubate and monitor anesthesia (unless a veterinarian chooses to do so themselves).  If an LVT/RVT/CVT are unavailable, a veterinarian should directly oversee (or directly perform when needed) intubation and the monitoring of anesthesia.  In cases where a licensed technician is not available, it is very important for a veterinarian to be present during the entire anesthesia process." - Dr Lauren Kloer

B. Injections involving anesthetic or chemotherapy drugs, subgingival scaling, or the placement of intravenous catheters shall not be delegated to an assistant. An assistant shall also not be delegated the induction of sedation or anesthesia by any means. The monitoring of a sedated or anesthetized patient may be delegated to an assistant, provided the patient is no longer intubated and provided a veterinarian or licensed veterinary technician remains on premises until the patient is fully recovered."