We are writing in regards to the proposed regulatory changes governing the practice of dentistry in Virginia.  We are concerned that the new regulations could inhibit the utilization of sedation techniques that have been practiced safely and effectively by Virginia dentists.  There is a great need among the population of Virginia for access to dental care where anxiety and fear stand as obstacles.  The utilization of sedation is often the only way to provide dental care to handicapped individuals, medically compromised, or phobic patients with a high degree of safety and effectiveness.  Virginia dentists have an excellent safety record and in-office emergencies are actually reduced by the use of sedation.
  We think that it would be useful to compile more data on sedation as utilized by dentists in the state of Virginia before any regulatory changes are made.  There is no current list even available of  dentists who incorporate intravenous sedation in their practices.  We do not know how any regulatory changes would impact existing practices because there is no data on the types of sedations, patient monitoring, or kinds of drugs that are being employed.  Different drugs and drug combinations create very different levels of sedation with distinctly different margins of safety.  Our experience has been that there are as many types and techniques of sedation as there are doctors using them.
 Dentists in Virginia are very highly educated and we believe have proven themselves very competent in performing sedations safely and effectively for many decades.  These dentists are well trained and capable of deciding what equipment is necessary for monitoring patients and what training is needed by ancillary personnel in their practices.  The use of sedation in all of its forms should be made widely available to all dentists who feel comfortable applying these anxiety reducing techniques to the benefit of the people of the Commonwealth.  There should be and are guidelines for sedation, but dentists should be able to adapt their own techniques into their practices in ways that they feel are practical and effective. 
 Of specific concern are proposed changes which include general anesthesia and any form of sedation in the same regulation.  There are many forms of conscious sedation with wide margins of safety that do not necessitate the same level of regulatory control as deep sedation or general anesthesia.  More opportunities must be given for input on any new regulatory changes by the dentists whose ability to provide this essential service will be affected.  Thank you for your consideration.

Sincerely,
Dr G. Preston Burns III and G. Preston Burns Jr., D.D.S., P.C.
Fredericksburg, Virginia