Dear Sirs,

I would like to comment on the proposed changes to 18VCA150-20-172 Delegation of Duties for the Board of Veterinary Medicine.  Specifically:  The monitoring of a sedated or anesthetized patient may be delegated to an assistant, provided the patient is no longer intubated and provided a veterinarian or licensed veterinary technician remains on premises until the patient is fully recovered.

Unfortunately, if this regulation is implemented, this would place the burden of monitoring an intubated, anesthetized patient on either a veterinarian or a licensed veterinary technician (LVT).  We find ourselves unable to hire enough LVTs to perform the tasks now required by regulation.

I fear that the limitation of the staff authorized to assist and monitor during even minor procedures, or common procedures such as dentals and extractions, would tremendously increase the cost to the owners, without increasing patient safety.  Thereby decreasing the availability of these procedures to the majority of the pet owning public.

As an alternative I would suggest each hospital submit their veterinary assistant training program for Board review and approval, to ensure that staff involved in any anesthetic procedure are trained to competently ensure patient safety.

Thank you for your consideration,

Karen E. Bates, Hospital Manager