Regulations Governing the Practice of Dentistry [18 VAC 60 - 21]

I am writing to voice my opposition to the proposed changes with oral conscious sedation. Our office has been oral sedation certified for almost 3 years and we have treated over 150 sedation patients without any incident. This is already a proven safe modality of treatment when the current regulations are followed. These patients are people that have avoided dental treatment for years – sometimes decades - due to their great anxiety associated with dentistry and needles. I fear that without this option we will create an unnecessary barrier to care preventing patients from receiving the help they need. The availability of oral sedation has made it possible for many patients to move forward with care.

In our office, we generally use a combination of nitrous and Triazolam – generally about .5mg of Triazolam and sometimes up to.75mg if the patient is large. The proposed limiting of dosage and limiting sedation to just one medicine would limit the successfulness of sedation as one dose does not fit all patients. The dosage of Triazolam that is needed for sedation varies according to the patient’s size, other medicines they are taking and their reaction to the sedation medicine. However, by using nitrous in combination with Triazolam, we don’t have to use as much Triazolam. By limiting the dosage or only allowing one of the medications, that will mean some patients are not adequately sedated to eliminate their anxiety about dental care and they will not have a comfortable, positive experience.

Our patients mostly choose oral sedation over IV sedation because they don’t like an IV needle. Additionally the cost for oral sedation is significantly less than IV sedation allowing access to dental care to many who more are financially challenged. If there are concerns about any specific incidents, then that office should be visited to make sure the current guidelines are being adhered. A much better way to increase patient safety is to do more training rather than restricting the dosage of sedation medications. When the current guidelines are correctly followed, time has proven oral sedation is safe and allows access to care for many people that otherwise wouldn’t get dental care. If we hope to improve public dental health we should be aware of our patient’s needs and the barriers they face when seeking treatment.

I am opposed to the proposed guideline of having 3 people in the sedation operatory. We always have 2 people there but a third person is not needed. The ADA guidelines just recommend 2 people. There are always others in the office that are close by and could come to the room if needed.

I would like to voice my feeling that this regulation would actually limit patient safety because people may not seek needed dental care, perpetuating a state of unhealthiness if their only option is to have IV sedation. I feel these restrictive guidelines are not the answer, not needed, and do not increase patient safety.

Best,

Dr. Joseph McIntyre DDS

Smiles for Life Dental Care

115 Oakwood Dr. Bridgewater VA, 22812