First I would like to agree with you on wanting to place regulations on oral/moderate sedation; public safety has to be the priority. I have practiced oral sedation since 2001. I have taken hundreds of hours of continuing ed in sedation and have received both the Felowship and Diplomat awards from The Dental Organization for Conscious Sedation. I have all the required emergency equipment so I feel my patients are safe. In all the years I have done oral sedation I have not had what I would classify as an emergency situation. I agree with most of the regulations you placed but have a concern with ywo. First, requiring EKG monitoring for oral sedation. While EKG monitoring is the gold stantard for IV I feel it is overkill for oral sedation. The pulse oximeter is very capable of providing the monitoring for oral sedaton. In oral sedation the patient is awake and responds to both verbal and physical stimuli. The pulse ox plus is what I have used for years. It allows great monitoring for my patients. Second, trained office personel should be able to monitor a patient while the dentist is checking a hygiene patient in the next room or operatory. Our assistants have to take training courses so they should be able to monitor oral sedation patients as long as the dentist is in the office and nearby. My assistants are extremely capable of this monitoring and I am always within 100ft or so. I hope you will take these comments under consideration.