Page 12, under "Medic" - what about EMT-Enhanced?

Page 17, under "Registered Nurse" - strike the words "an individual" after the word "means"

Page 42, 12VAC5-31-390 - The sentence "EMS agencies shall have a component of their OMD approved patient care reports; a triage component consistent with Code of Virginia mandated state specialty care hospital triage plans." does not read right.  Perhaps missing a word or two?

Page 50, 12VAC5-31-540 - Why is it necessary to have a driving record transcript if the person does not operate vehicles?

Page 54, 12VAC5-31-610 - the term "responding interval" should be changed to "responding time" as this was changed in the definitions.  This occurs in various places throughout the regs.

Page 55, A.2.a - unit mobilization interval standard should be stricken from the rules as it was deleted  from the definitions.

Pages 76,78,79 and 80 - strike the number "4" as was done for all other numbers.

Page 87, 4.g - the term "medical protocols" was deleted from the definitions.  I suggest that the term "Prehospital Treatment Protocols" be used in order to cover all treatments, regardless of the nature of the injury/illness.  This is also on Page 92.

Page 99, D - Why is the EMT-enhanced (lower case?) package different from the AEMT when the two are essentially the same?

Pages 101 4.7 and 102 5.e - Can "End Tidal CO2" be added to the wording to emphasize the importance of this as a standard of care?

Page 104 C.2 - last sentence "per the agency's policy required in 3.a"  There is no 3.a that I can find.

Page 105, 12VAC5-31-885 - "The air medical agency shall have a planned and structured program that  all medical transport personnel must participate in."  What kind of a planned and structured program?

Page 106, B.6 - EMT-B should read just EMT.  This should be corrected throughout the book if we are going to follow the national levels. 

Page 116, 12 VAC5-31-900, 2. "Be clean and neat in appearance;"  Who is going to define this?  Hair length, color? Tattoos? Piercings? All the time? On a single incident?

Page 132, 12 VAC5-31-1230, 1. - The operator of the vehicle needs to have some medical training if they are going to be a part of a two person crew.  I would prefer to see EMT required.  My experience is that it is a terrible thing to be on an ambulance with a driver who does not know what a suction unit is, or a bag-valve-mask, or a non-rebreather mask.  Or, try teaching a non-trained person how to backboard a patient on the scene with an injured patient.  Or, arrive on the scene of a motor vehicle crash with two injuries and one person has no idea how to treat the second patient.  This is 2010 and the standard of care should be that there are at least two trained people on an ambulance. Certainly most of the ambulances in the state operate with just two people and it is not fair or safe for one of them to be untrained.  Doing this could eliminate the need for item 3 in 12 VAC5-31-1250.

Page 133, item 4, last sentence - "Based on extenuating circumstances and documentation, the EMS agency and/or the EMS provider may be subject to enforcement action."  What does this mean?  You do what is right for the patient and then might be cited for it because you didn't have an EMT on the ambulance?  This fully supports my position stated above.

Page 145, Why do EMT instructors and ALS Coordinators have a two year certification period, yet the EMS Education Coordinator has a three year certification period?

Generally speaking, there needs to be more cross referencing of the new levels with the existing levels.  For example, where the level First Responder is written there needs to be a reference to Emergency Medical Responder.  Same goes for EMT-Enhanced and Advanced EMT.  There needs to be a better way to talk about the new levels and the existing levels in the regs that makes sense.  Take away all references to EMT-B if the new level is just EMT.  Take away all references to EMT-P if the new term is just Paramedic.

Thanks for the opportunity to provide input.