I was a board member when the regulatory review and proposed changes were being discussed. The new wording was added to protect the public so that a veterinarian or Licensed Veterinary Technician remained on premises during all phases of an anesthetic procedure, including recovery thru extubation and consciousness of the patient. We are all busy, and juggle many tasks, requiring delegation of duties.  Please remember the following from the AAHA anesthesia guidelines, (Most anesthesia deaths occur during recovery, especially in the first 3 hours)  Previous regulatory language implied veterinarians could delegate the administration of scheduled VI drugs ( non controlled) to patients prior to their arrival on premise, or not having a licensee in the clinic while a patient is still recovering from anesthesia.  That is the VALVT’s concern. This could include expediting patients for surgical procedures, patients requiring sedation for grooming or non complicated dental cleanings.  While we believe it is clear that veterinarians understand it is ultimately their responsibility to care for his/her patients, some may feel the need to take that risk, due to case load, or staffing issues.  Is it really the best for patients put in their care?   We believe it is the perception of the public that while their pet is undergoing a procedure whether it is sedation or general anesthesia that licensed personal will be in the building overseeing the care of their pet until fully recovered. 

I along with members of the VALVT, suggest the following wording under the delegation of duties so as not to restrict the veterinary team, and not cause economic hardship

Induction of anesthesia, sedation, or chemotherapy drugs, subgingival scaling, or the placement of intravenous catheters shall not be delegated to an assistant. The monitoring of a sedated or anesthetized patient may be delegated to an assistant, provided a veterinarian or licensed veterinary technician remains on the premises until the patient is conscious.

In closing, as veterinarians and technicians we strive to do the best every day. We should not loose sight of the publics perception, and common sense when they leave their pet in our care. We feel that the above recommendation will satisfy and protect everyone including the public, our patients, and the veterinary community. 

Respectfully Submitted

Taryn Singleton, LVT