I am writing in support of the proposed change to this regulation for the following reasons:

1.) The proposed regulation will reflect the actual intent of the regulation. It was meant to prevent, or at least deter, personnel from showing up at work or for duty and operating emergency vehicles while under the influence.

2.) The current regulation includes convictions for DUI that occur in private vehicles when personnel are not on duty or on the clock. A conviction while driving a personal vehicle prohibits operating EMS vehicles for 5 years. Since operating apparatus is a key component in most job descriptions, this will normally result in loss of employment. This was not the intent of the original regulation.

3.) The proposed changes do not eliminate penalties for off-duty DUI convictions, they simply put the responsibility on the jurisdiction. Some jurisdictions, such as King George County, already have personnel policies that are far more stringent than the current VA Code in regards to DUI convictions. Providers who have waited the current 5 year period, would still not be eligible for employment there.

4.) The proposed regulation does not lower the Standard of Care that patients receive in Virginia. Someone who operates EMS vehicles under the influence would be dealt with even more severly under the proposed regulation than the current one.

Again I fully support the proposed amendments which will allow this regulation to serve it's designed purpose.