I have reviewed the proposed Interdepartmental Standards and I am requesting that the following items be considered for revision:

22 VAC 42-11-640.H--Records should be retained and disposed of in compliance with the Library of Virginia's General Schedule 24 relative to maintenance of juvenile records.  In the case of detention facilities, maintaining records indefinitely is a fiscal burden to the tax payer and serves no purpose since these records are duplicative of most information maintained by the courts. 

22 VAC 42-11-860--This item should be N/A for secure detention.  Secure facilities should be permitted to implement behavior management programs conducive to the needs of a secure environment.

22 VAC 42-11-810.F.6--Medication should be administered consistent with the 22 VAC 40-72-670 and the Board of Nursing approved training for medication administration; i.e. the recording of "actual time" in the proposed standards is not considered as an industry standard. 

Finally, I request that a definition be provided for "post-disposition" that is consistent with language contained in VA Code 16.1-284.1 regarding the placement of juveniles in a secure facility.