I am writing to oppose the changes in the following paragraph: 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.

This change would be impossible to implement in many practices due to the limited number of LVT's in Virginia. In practices with numerous LVT's the regulation would dramatically increase surgical costs to the owner.  More importantly the burden of safe anesthetic procedures  should remain under the control of the veterinarian. An appropriately trained assistant is capable of monitoring an anesthetized patient throughout a surgical procedure.