I am writing to express my great concern regarding the recently developed regulations for sedation in dental treatment.  These regulations are unnecessarily burdensome on dentists who want to practice sedation dentistry for the comfort of their patients.  The regulations will drive up the cost of dental care significantly, they will decrease the number of dentists who offer sedation treatment, and they will result in more dangerous treatment for patients.  Following is an explanation of my contentions:

1. The regulations require dentists to purchase an EKG for monitoring patients during even mild to moderate sedation.  This machine could cost in the area of $5,000, and its output would be a waste, because it would not be constantly monitored during treatment, thereby making much of its data meaningless.  

2. The regulations would also require dentists to be in the room for the entire time of the sedation treatment.  If this does not change, then dentists will have to charge far more for sedation appointments than currently.  Right now an assistant or hygienist who has been trained can monitor the sedation, with the dentist still in the building and able to respond to any irrgularities.  Requiring the dentist to be in the room the entire time will make the cost of treatment far greater, thereby decreasing the number of patients that can afford it.

3. It appears that the board must be afraid that sedation dentistry poses a serious threat to the health of Virginia patients.  However, in reality, mild-moderate sedation makes treatment of patients far safer, especially if they are nervous or have heart problems. It keeps them calm and relaxed, and they also heal better after sedation treatment.  

4. It is also unfortunate that the regulations do not distinguish between deep sedation and mild-moderate sedation.  I believe the regulations are unduly harsh for the mild level of sedation that is induced parenterally.

5. The American Dental Association has spend considerable time developing guidelines regarding appropriate use of mild-moderate sedation in dentistry.  They do not require the use of an EKG machne, and they do not require the dentist to be in the room constantly.  Perhaps we should follow their lead.

6. There is no state in our country whose dental sedation regulations are as severe as Virginia's.  This is over-regulation, the patients would lose out if the regulations are not changed.

For the reasons above, I hope that the Virginia Board of Dentistry will reconsider its current regulations and do what is truly in the best interests of our patients and oru profession.

Sincerely,

William Griffin, DDS

Newport News, VA