After reviewing the proposed Sedation requirements for the state of Virginia and discussing the proposal in detail with colleagues, we are in agreement that the regulations have a few problems that need to be addressed.

1. ECG monitoring for Moderate Sedation is not necassary to provide proper monitoring for moderate sedation. According to the Academy of Pediatric Dentistry, American Academy of Pediatrics and American Dental Association the following is recommended during moderate sedation (different from Deep Sedation):

During the Procedure
The practitioner shall document the name, route, site, time of administration, and dosage of all drugs administered. There shall be continuous monitoring of oxygen saturation and heart rate and intermittent recording of respiratory rate and blood pressure; these should be recorded in a time-based record. Restraining devices should be checked to prevent airway obstruction or chest restriction. If a restraint device is used, a hand or foot should be kept exposed. The child’s head position should be checked frequently to ensure airway patency. A
functioning suction apparatus must be present. (from the guielines of the AAPD)

ECG monitoring should not be required prior to, during, or after moderate sedation procedures.

2. Continuous monitoring of the patient for moderate sedation should not be required prior to starting the dental procedure.

Most of the time the reason patients are recieving medications for sedation is because of precooperative behavior or uncooperative behavior. The medications are given after baseline vitals are measured and checked and then it takes time for the medications to take effect and peak in order to start the procedure... the patients will not sit in a room and leave monitors on for the 30-45 minutes prior to starting the precedure with the dentist in the room watching the patient bounce off the walls. The area should be quiet, with the parents, and nonstimulating prior to starting the dental procedure, without the dentist in the room. Office personel should be able to monitor the patient prior to starting the procedure with the dentist. When the patient becomes drowsy by the medications, then monitors can be placed and the dentist can start continuous monitoring for the procedure and able to discharge the patient when appropriate according to the guidelines. 

Please consider all recommendations suggested in the comment section when finalizing the sedation regulations and distinguish between Deep and Moderate sedation monitoring requirements. Eliminate the requirement for ECG monitoring equipment and continuous monitoring by the dentist.

Thank you for your consideration, 

Shepherd Sittason D.D.S.