There should be provisions for practitioners who do not administer local anesthetics in their office setting.  Currently there is no ACLS focusing on the dental setting.

I am in support of this petition.  

I am opposed to this new regulation.while it is very unfortunate these 2 deaths occurred,I do not believe they are necessary nor would they change future unfortunate deaths.  Every dentist I know already is prepared to handle these situations.  I believe it is already the standard of care to be trained and equipped to handle these emergencies in a limited way until EMS is onsite. Even one death is too much, but I don't.think a regulation will prevent future deaths.  To have two deaths in what has to be millions of office visits shows it is less likely for someone to die in a dental office than many ordinary daily activities.

It is the responsibility of ALL Virginia Regulatory Boards to protect the public.  Any death is is one too many, but statistically it is probably safer to go to the dentist that cross the street.   These proposed regulations are already the Standard of Care in most offices.   A regulation such as this would cost hundreds of thusands of dollars for most practicioners to follow; meaning the time spent documenting training, paying for training for a large staff when not everyone needs to be trained at the same level, etc.  So who pays for all this unnecessary documentation and training?   The average Virginia resident in the form of increased dental fees.   Is this what we want for our patients?

I would oppose action by the Virginia Board of Dentistry to adopt the Petition for Rule-making with conditions to seek renewal of a dental license.  It is government interference and micro-management to demand  blanket compliance.  Dentist are caring and  compassionate  health care providers who already overwhelmingly  meet the emergency needs of our patients without a Board mandate.

I think that we as dentist are already prepared and trained to handle emregencies in our dental practices and this is just another goverment hoop that we will have to jump through at the expense of our patients. Although it is unfortunate that there were 2 deaths, the percentage of dental procedures daily in thousands of offices prove that we already have a handle on the protocol of handling emergencies in the dental offices. There is already the law in place for those that do sedation to have certification via the DOCS program so I think that is more than adequate to take care of our patients in the case of a medical emergency. Maybe let's focus on better health histories, refusing to do a procedure if blood pressures are at a certain level, and be more proactivce but not reactive in more training. We are already trained. Maybe the Board of dentistry should supply us with a "standard medical history" that makes sure it asks all the right questions, or a standard medical history update each time the patient comes in. Since we all use our own Medical History forms and updates...maybe that is where the focus needs to be to help us screen better for possible medical emergencies.But you always have the situation that the patient might not supply us with the Complete Truth---so that they CAN be treated and we aren't fully informed of possible medical conditions. I think this is a knee jerk reaction and needs to be weighed out more heavily of "mandated training and equipment" might not be the Best answer !  

I googled the "Six Links Guide" and my heart goes out to the Blanco family for their tragic loss; however I mirror Paul Callahan's sentiments.  How will the board enforce compliance?  Who  will perform the inspections to police the requirements and  what about the need for a search warrant?  Who will pay for the enforcement  and what are the consequences should one fail to abide by  all the requirements?  For example, if a dentist must have a commercially available crycothyrotomy kit ( or stated  alternative ); is he or she then required to use it in an emergency and  what happens  when our  frantic effort  causes more harm before EMS arrives?  Most of us  are  caring professionals, and the "Six Links" provides a noble blueprint for us all; but it should remain a voluntary one.

Has there been any study to indicate that such a new, broad training requirement for dentists/staffs would have saved the lives of those people that died?  There are plenty of solutions out there in search of a home as we've experienced from the dental supply industry.  The true costs in time and dollars and the benefits of a bureaucratic approach do not seem to be a wise investment to me.  The buying -in by the leaders of the dental profession, without exposing the strategic costs, is unwise in today's litigious society with a political leadership that is actually looking for ways to cut costs.  I see this as just another step down the road to making the dental operatory into a surgical suite in the face of a favorable cost/benefit analysis that is not there. There is an ongoing regulation of the solo practitioner out of the profession, for no good moral reasons other than the pursuit of a political power game that having dentists on a Regulatory Board is intended to avoid, thereby protecting all concerned in a strategic sense.

Recommendation: The Board to table this request without action unless it can disapprove it outright, with a solid cost/benefit analysis that exposes the strategic negatives to the proposal, if that analysis would be required due to the political nature/tailwinds of this proposition.  I am even reluctant to outlay dollars for such a study to start down this path.  My only real concern here is how much effort will be needed to head off this "progressive" movement in the face of all the realities "on the ground"? 

I am uncomfortable with givng this sort of proposal any support so that other future Boards might leverage even any minimal support now into a larger movement in the future. The dental societies and the medical insurance industry, on their own, are probably the best proving grounds to provide the current, appropriate level of  training without a heavy-handed regulatory approach.

Thank you for allowing this consideration in this forum and for the important and difficult work you do in your advisory efforts to be an honest broker between the public and the dental profession.

I oppose the extra regulation. All dentists are already certified in CPR.  Regular re-certification is also already mandated.

This Raven Blanco Foundation may be a plublicity stunt to raise funds, that support their self created non profit slary jobs. Everything about their web site is very exploitive. They list no financial discloures, no board of directors/advisors. They are certainly following the guide for creating an issue that will bring them money and influence, and as they say power. And like all these nonprofits, they appeal to ones suffering to gain support.  They can be dangerous, just like all of our local dental nonprofits, run by non dentist, unlisenced advocates if you will, who want to be policy makers over dental matters of which they are trully ignorant. I would question the credibility and intentions of this group. Leave the emotional baggage out of any descision making. Dont treat victims as equals, they are not!

I oppose this proposal for several reasons. First, all dentists are trained in CPR. Second, these rules will not prevent additional deaths. Third, adequate training should be spent in screening patients properly (eventhough patients constantly omit information in their medical histories). Please do not over-regulate. Let common sense prevail. Thank you.

This petition has no basis in reality.  As dentists, we all know how to respond as indicated in my Subject Line.

If you pass this regulation, it is not only going to cause a large financial burden onto us (the practitioner), but also the patients that we see.  We will have no choice but to increase our fees to accommodate these changes.  Aren't  the insurance companies already making things bad enough? Does our own legislature also have to contribute to the publics financial burdens?  Don't let a couple of very unfortunate events cloud your judgement.  How long have Dentists been practicing dentistry and how many deaths have occurred in all those years?  You must look at the bigger picture and not at the smaller one just because you feel pressured by media or whom ever.  Do the right thing and rescind this nonsense.

Adding additional regulations will increase the cost of dentistry.  More importantly, what is the need for additional regulations based on.  Where is the data that demonstrates the need for additional regulation and additional training (well actually proof of training since dentists are trained to handle emergencies)!

 It's my feeling that the "Six Links of Survival as a condition of continuing licensure" would be an unnecessary burden to place on a dental practice.  We take courses in dental emergencies and emergencies in a dental practice.  Dentists are required to have BLS (CPR) training and some opt for ACLS.  I have been a strong believer and was using gloves & masks, autoclavable handpieces, water line treatment, and AED's   before being required by law. 

Please consider the cost benefit before developing regulations  in a situation where the system is working.

I am not automatically opposed to a standard, but

1)  Who is proposing this petition for rulemaking?  Is it a special interest group, as in a group of malpractice attorneys or some organization that "sells" CE or inspection services to offices that want to register compliance?  I would like the Board of Dentistry to respond to petitions from dentists, not special interest groups, and respond to petitions because they are a good idea, not because special interest groups have their own agendas,.  Recent example:  Sedation permit.  Who originally pushed for that?  I believe it was a malpractice attorney who stated, in the petition, that "most conscious sedation leads to deep sedation"--I have read no data to support this, and I contacted him and asked him to provide me with such data--he could not respond.  And, here we are, a couple years later, in the process of requiring a sedation permit for conscious sedation/deep sedation.  I'm not against a permit, but the proposal is worded as though the Board bought into his flawed philosophy that conscious sedation and deep sedation are paired together.  If anything, conscious sedation is closer to anxiolysis, whereas deep sedation is closer to GA (Don't take my word for it, look at the definitions established by the American Association of Anesthesiologists  And, believe it or not, I'm actually in favor of a permit...I just don't like the though processes involved in developing one).

2)  If you do this, then I think the BOD has to make sure that systems are in place in the state of Virginia, easily accessible and relatively inexpensive, to allow dentists to be in compliance.  You can't just make a rule and not have the the resources readily available to practicioners to support it.  (I have the same comment with respect to the sedation permit).

3)  If it's a permit process, is this yet another permit fee for the dentists of Virginia?  (Same question with respect to sedation permit...)

4)  Who will do the inspections?  GPs?  Oral Surgeons?  EMS personnel?  (Same question about the sedation permit.  We are supposed to be applying for those permits now, without any indication as to what they will require, who is establishing the requirements, and how the "certification" will take place).

I am opposed to any more uneccesary regulation, this six steps program is just the latest attempt by someone outside of the profession who has an agenda they are attempting to impose. Currently there is a system in place that will handle any potential shortcomings that unfortunately befall people whether in the dental office or the shopping mall. In this day and age of government interference into the lives of citizens it is time for the profession to realize that we cannot prevent every malady that befalls the public. Life is full of potential disaster, such mishaps happen, and in many cases due to some individuals lack of personal responsibility to prevent their own mishaps. Obviously this is not the situation in every case, but the exceptions to this lack of personal responsibility are so few and far between that the undue regulation of all for the sake of the few if not tyranny is close to it. The times are a changing and the trend is away from such folly not towards more of what has placed us in the dire situation that we all face today. Enough government, we've had enough!

R. S. Mayberry DDS

I am opposed to the additional regulations.  Dentists are already trained to manage emergency situations and, if they are using sedation dentistry, are required to obtain regular recertification to keep emergency management skills current. Thousands of sedation cases are performed every day to a successful outcome.  Additionally, whether we are using sedation dentistry or not, emergency situations arise in dentistry and are managed to a successful outcome due to our current standard of emergency care.  While it is devastating to lose someone in any situation, adding regulations to an already sufficient training protocol will not eliminate these rare events.

How many more children must needlessly die before dentists are  held accountable? 8 Children in the past year have died while undergoing "routine" dental procedures.  IF  dentsits were required to have the training and equipment in their offices,  perhaps a life could be saved.  

I absolutely believe that all dentists in Virginia should take Medical Emergency Preparedness Continuing Education Training, before they renew their license. This way, they can be fully prepared  to save a life in the event of an emergency. There should be no question about this! Their patient's safety should be their number one priority. Anyone - dentists included - would want the same for their loved ones.

I absolutely believe that each and every dental practice need to institute the six links of dental emergency preparedness, before liscences can be renewed. I don't understand why professionals would be opposed to keeping their practices prepared and as safe as possible. We wouldn't be encountering so many emergencies and tradgedies, if offices were properly equiped and prepared to handle such situations. You can never be too prepared in my opinion!  

Please ... please..  please ... something has to be done.  These poor families have to suffer needlessly.   Medical professionals must be required to have emergency training and be required to be updated for  new proceedures that are being updated as we speak... Traning is key to our childrens well being....  something must be done!!!!

Strongly WANT, seems the only dont wants are DDS. Well Im sorry this will be an inconvinience to you but, Im tired of watching children die and get seriously hurt where simple steps could have been taken to prevent it.. Do it for the children if nothing else!

I am a Nurse Anesthetist and used to give anesthesia in dental offices. I am amazed at the lack of safety that is allowed in dental offices nowadays. There MUST be a person in 100% attendence during anesthesia to the patient. The staff must be trained in advanced CPR. You cannot assist the dentist and watch the patient at the same time. This would never be accepted at a training institute and should never be accepted in private practice. It is pure greed that the dentists charge for anesthesia and no longer employ someone who is qualified to give the anesthesia and monitor the patient 100% of the time. At any moment, a patient can have an unexpected reaction or a wisdom tooth removal can turn bloody or a tooth pop into a sinus or any unexpected complication. If it was you or your child or family member that was in danger ....you would want 100% safety precautions!!

I understand the concerns reguarding the increased time and money involved with implimenting this. I have to wonder  though if you lost a loved one because a dentist you trusted to care for you child was only able to perform basic CPR wich is the same care that would be expected at a daycare center, would you feel the same?

Don't get me wrong, I think basic CPR is great and everyone should learn it.  I also think AED's should be in every school, daycare, mall etc.  BUT the idea that a dentist could administer a sedative that could cause respiratory compromise and in turn cardiac arrest, could not be prepared to provide Advance Cardiac Life Support in addition to CPR is frightening!  Every minute that passes during cardiac arrest, the patient's chance of survival decreases significantly.  Statistics on this are a dime a dozen.  Unless you have an ambulance waiting in the parking, it is very rare that one will arrive in less than 6 minutes and often much longer.  That is until they pull up to the front door.  You also have to consider the time it takes to unload equipment, locate and assess the patient and then start ACLS IF there is a Paramedic on the ambulance.  Not all EMS agencies are ALS, there are many that can only provide Basic Life Support.  So why would you as dentists not want to be equipped to begin the life saving ACLS protocols as soon as possible to provide your patients with the best possible chance of survival?  Because of cost? time? money?  the belief that it won't happen to one of your patients?  Exactly how many deaths have to occur before the inconveniences are justifiable?

A few years ago my son had a dental procedure that required sedation.  I wasn't a Paramedic at the time so I wasn't aware of the possible complicationa and I certainly wasn't equipped to ask the appropriate questions to ensure the staff was prepared in the case of an emergency.  I was ignorantly blissfull.  I was very fortunate.  His procedure went as planned with no complications.  Many other parents have not been as lucky.  I keep seeing "two deaths"  this is proof that I'm not the only one that has had the pleasure of ignorant bliss.  There have been many more than that.  Is there an agency that accuratly tracks all deaths related to dental procedures nation wide?  I haven't been able to find one.

I don't work for this foundation, I'm not a family member or long time friend.  I just recently met them but I can tell you this is in no way financially driven.  This is driven by a father that misses his daughter every second of every day.  A family that has decided to face their grief day in a day out rather than try to move on so other families don't have to suffer the way they have.  Their courageous efforts should be celebrated.

I strongly agree that the state of Virginia should make it mandatory for Dentist to take a Medical Emergency Preparedness CE Course to renew their license. It's important to know that your kids as well as yourself are in great hands in case of an emergency. Would you want someone you don't know, care for your kids without the proper CPR training? This is the same thing and we can control how many times kids loose their life during a simple dentist procedure by making this mandatory, 

Saying no to this petition is like saying no to the lives of children. We can not stand by and allow dentist office to continue to not do what is necessary or more than enough to be prepared. The safety of our children is top priority. I ask....no...I plead that you pass this petition. Our children...your children...your grandchildren and all children will thank you for it.

YES

I support proper training for Dentists in order to have conscious sedation. I've been in a dentist office on more than one occasion while they try to awaken a child who is not waking up properly after a "routine" procedure. Why would anyone oppose having the means to revive a CHILD in that situation?

raven maria blanco was my niece. she was only 8 years old when she went to the dentists for routine work and didnt come home. they didnt even have a defibulator in the office. i support this cause and dont understand why any dentist would not. obviously they have not lost a child this way. i should think they would want to do all that they can to educate themselves and be prepared. so what if at takes up your time and a little money. i would rather know that i did all that i could and took every class available to me and my staff than have to live with a child dying under my care and wandering if i had done enough.for those who say the organization is trying to profit, shame on you.my sister and brother in law suffer everyday with this loss 4 years later and always will. DO THE RIGHT THINGype over this text and enter your comments here. You are limited to approximately 3000 words.

I am against any type of legislation like this.  I was reading something last night from Kellogg, the guy who is supporting the mid-level providers.  To support his case for mid-levels providers he talks about the increasing costs of dental care.  He says that the cost of dental care is increasing faster than the rate of inflation.  This medical training will require time away from our practices and financial resources.  These fees will then be passed onto the dental patient in terms of higher fees than what we are already charging.  Is this what we really want?  Are Kellogg's stats wrong?

I go once a month to an infusion center where chemotherapy is administered.  On numerous occasions over the past four years I have witnessed medical emergency with the administration of chemotherapy.  In every instance I am amazed at the staff and their response to the emergencies.  Does this take training and practice?  Of course it does.  Are we administering drugs that frequently require a response like this?  I don't think so.  I would have to say that most dentists go their entire careers and never have a medical emergency like what I see in the infusion center.  I thank God for that.  I say all this to say, that medical emergencies are rare in the dentist office.  I am not against being prepared for medical emergencies in the dental office but I am against mandating that dentists be required to go to this extreme of medical emergency preparedness.   CPR training has been good enough for all these years.  ACLS training is already required for those doing sedation.  This seems like an additional step to ACLS training.

Thank you for the opportunity to express my opinion.

I STRONGLY agreeI stronley agree that dental practices should require training and equipment for medical emergencies for licensure and renewal. There is no such thing as TOO much training, why not take the oppurtunity to gain more knoweledge, if an emergency were to occur in your presenece wouldnt you feel better knowing you could help? Calling 911 isnt the proper soulution, neither is CPR.  Will emergencys still occur? Yes, but at least they will  be handeled in the right manor. I would feel much more secure knowing that the dentist I brought my child to has the proper equipment to handle andy emergency, I do wish this would go further then just dental offices... teachers should be prepared, recepitonests, etc. Help save lives ! PASS THE PETITION! SHARE! 

The proposal stated that Virginia had two deaths in dental offices or institutions in ten years. Is this a lot? Were the deaths related to dental treatment being rendered at the time? Is this incidence rate statistically significant? Would the deaths been avoided if there was a state mandated level of Emergency training in place(since one death took place in the dental school,it can be assumed that at least some of the faculty were trained in advanced cardiac life support, and yet even that level of training,the death was not prevented)? My understanding is that CPR certification including use of an AED, is a current requirement for licensure. The content of criteria for this is standardized and well known. What would be, and who would set, the criteria for training, certification and monitoring of proficiency? If the Board, where would the budget for this additional responsibility come from? While I agree that all practicing dentist should be prepared to deal with a medical emergency arising in their office, the effect of requiring evidence of such training places a huge expense on both the dentist and the monitor(presumably the Board) without actually guaranteeing preparedness in a particular case. I would encourage all my colleagues to take a medical emergencies course if the have not recently done so, and to have staff training in dealing with an emergency, but i think adding an additional requirement for licensure is regulatory overkill. It will increase paperwork and expense without achieving the goal it seeks to attain

A parent taking their child in for a dental check up should not have to worry about whether or not their child will make it out alive. 

FACT 1:  Most medical emergencies occurring in dental offices are neither life-threatening nor cardiac in origin (Malamed, USC).  To argue that CPR is all that is required is naïve and statistically wrong. 

FACT 2:  Calling 911 is NOT an emergency plan.  Nationally, the AVERAGE response time for EMS is 11-15 minutes.  Dental offices should be able to manage ANY medical emergency (diabetic shock, seizure, MI) for at least 30 minutes without outside assistance.

FACT 3:  Currently, the American Dental Association has no standardized guidelines for medical emergency preparedness by dentists.  If dentists do not have standards for medical emergencies, only the Board of Dentistry remains to protect the interests of the public.

Fact 4: Curiously, many offices have oxygen for ONLY non-breathing patients.  Apparently, many dentists believe that when a patient is struggling for oxygen, the best strategy is to let them stop breathing before helping them.

FACT 5: Not all medical emergencies are complications of sedation/GA.  Sharon Freudenberger, Associate Professor at CWRU Dental School was working on her son’s tooth when a piece of gauze slipped into his throat. Fortunately, she was prepared and her son is still alive.  Unfortunately, a child in NJ died last week while receiving local anesthesia in an office that was already on probation for a previous death. Additionally, Dr. Yagiela, noted author and lecturer, stated that there has been a death in every state from local anesthesia.

FACT 6:  Dental leaders in medical emergency management know medical emergencies routinely happen and have concerns about the profession’s state of readiness.  Malamed has described the current state of affairs as, “Poor” and went on to state, “Office preparation is essential…”  Haas said, “The successful management of a medical emergency is one of the great challenges in dentistry.”  Rosenberg said, “Every dentist will likely manage a medical emergency during the course of their practice.” 

In response to, Watchdog for Coalitions Against The Dental Profession (CADP), which I couldn't find any public information on at all...

•    I am the Executive Director, working as a non-salary employee.
•    Our combined staff salaries do not exceed $40,000 annually.
•    Mario Blanco, the founder of RMBF, provides 95% of all operating capital.
•    Since RMBF’s inception we have had a board of advisors. There is now a direct link to their page on our website.
•    Our 501 (c) 3  2011 financials will be made available to the public once completed.

FACT 1:  With an aging population (some with complex medical histories) being offered increasingly complex and invasive dental procedures, it is reasonable to believe medical problems occurring during dental appointments are increasing in frequency.  However, no academic research has been conducted by any US dental school for over 15 years. In the absence of evidence to the contrary and with a reasonable expectation that non-lethal emergencies are increasing, dental offices should be prepared for any unexpected circumstance.

FACT 2:  RMBF provided an 8-hour CERP-approved CE program on MEP last year.  The Virginia Dental Association endorsed and advertised the event.  Tuition was deliberately low.  Less than 12 dentists attended.  It is difficult to argue that Virginia dentists are self-motivated to prepare themselves for medical emergencies.

FACT 3:  Implementing the recommendations of the petition would not be a financial burden on Virginia dentists.  Assuming a dental office had no current preparations for an emergency AND they were willing to do any of the work themselves (eg preparing an emergency manual), products for everything else cost less than $2,750.  

FACT 4:  The petition does NOT call for mandatory office inspections nor does it require any expense on the part of the commonwealth.  Dentists would merely attest on an affidavit that they have complied with the requirements as part of license renewal.  Of course, to provide false information to the board would carry heavy sanctions.

FACT 5:  As expected, some rank-and-file Virginia dentists oppose the petition.  However, no dental educator or nationally-known lecturer has publicly opposed the petition or any of the concepts contained in it.  

FACT 6: If the Virginia dentists can protect the public without direct oversight from the dental board, it is their burden of proof to demonstrate that such means already exist.

Recertification yearly for BLS with AED training is necessary for ALL healthcare professionals since Lay persons shoud not be using this equipment unless properly trained, and although it may be required for licensure for dental professionals,  what use is it if there is currently not an AED on site.  An AED on site for patient safety will NOT increase the cost of dental care, and I am shocked to hear this from healthcare  professionals.  As healthcare professionals we take an oath to provide safe patient care, no where in that oath does it say that we will provide it as long as it fits into our budget!  That is compromising patient care, and in the end it is patients and families who suffer in the long run over the cost of a dollar.  Policy and procedure for sedation and anesthesia administration needs to be regulated at a level where there is continutity of practice and procedure, and it does not differ from office to office!    

All dentists in our state are required to have CPR training.  The board has just recently reviewed all the safety regulations in response to the increase in sedation dentistry. We do not need duplicate regulations for dentists that do not sedate patients. The foundation seeking these changes have weak evidence to support the need for these changes that would place a time and expense burden on dentists that are a very low risk population.  Do they have any evidence of death resulting from local anesthesia only? Please do not agree to a regulation change that we do not need.  

I am opposed to the 6 steps link. Dentists are required to do BLS currently. Why add an additional layer of confusion to the dentist and staff? Who will provide the training? How much does it cost? How much do we need to raise fees to add this additional training? It is too much interference. 

Currently the Board of Dentistry already has regulations in place to protect the public. All Dentists must be certified in basic life support. If you do sedation, then you are required to have ACLS.  The regulations are currently the strictest in the Country. The Dentists that do sedation should be and are well trained. I do not support the need to add more regulations; they are already in place.

This proposed regulation is not needed.  The Board of Dentistry has sufficient regulations in place to protect the public. Thus, the proposed changes in the regulations are not necessary and would be a burden to dentists and patients seeking dental care in the Commonwealth of Virginia who will be burdened with increased costs of dental care.  I opposed this Petitiion for rule making.

The petitioners' proposal is unncessary and burdensome.  Let me share my thoughts:

First, the Board of Dentistry recently approved new regulations for dentists who provide conscious

sedation, making Virginia's requirements among the most restrictive in the US.

Second, a large majority of dentists who practice in Virginia use only local anesthesia in their practice,

and there have been no reports of deaths due to local anesthesia in the dental office.

Third, all dentists are now required to be trained in CPR as a condition of their license.  Adding this

burdensome requirement will have the unintended consequence of suspension or loss of license for

many competent doctors, if they fail to meet the bureaucratic standard.

I would urge the Board of Dentistry to reject the petitioners' proposal.

For those who are opposing the new regulations...mostly D.D.S personel I might add...if what you say was true and dentists are sufficiently trained in C.P.R. then why would these deaths still occur. It is obvious that in the reform of current health care regulations there is a need for dental regulations as well. The Dental Community has failed to address the continuous problems sufficiently and because of this organizations such as RMBF have had no choice but to step up and advocate for the families and friends of the deceased. Those who accuse RMBF of less than noble intentions are those who do not want to be bothered with the extra effort to ensure the safety of their patients. It is a crying shame. I would be willing to pay more than double in dental costs so long as the safety of my child was ensured and I am confident that most families would feel the same.

The individual who claimed there have been "only 2 deaths" in the last year seems to not understand that 2 deaths is far too many and is not considering the fact that the 2 occured within the last 2 months. The actual number of the previous year is more than a dozen. Do we honestly need more than that to see there is a legitimate problem. Is costs and inconvenience really all there is to fight against?

I not only require but expect those who care of my children and the children of others to do what is necessary and then some. For all those who oppose this regulation on the basis of costs and inconvenience...shame on you!

Dentists are already trained in this area, and to further add to the existing requirements would be superfluous and costly, both with respect to time and money.  The fact that occasionally medical emergencies occur is not reason enough to increase the burden on  practitioners.  We need to get over this mentality that regulations can prevent every possible negative outcome... "if only..."

Please, please reconsider if you are thinking of passing these regulations.  I am an Oral and Maxillofacial Surgeon and I am getting recertified in ACLS this weekend for the fifteenth time.  Safety and emergency preparedness are already a part of our practice.  We do not need these onerous and redundant regulations added on top of what all of us already practice.  Please...no mas!

I am opposed to the six links petition.I believe the current requirements for basic life support (CPR  and emergency medical training) and ACLS  training  for those choosing to perform sedation in the dental office setting are sufficient for the protection of our patients.I feel this petitions' outcome would be a duplication of what is already in place.

No need for these rules.  Dentists are already well trained for medical emergencies.

After looking over the six links of survival I can see at first blush that it would seem appropriate for dental offices to implement such a system.  The fact is that, many offices have already done so informally.  Any office providing sedation will have these systems in place and staff training is expected and verified.  These are the patients most at risk.

I am opposed to the proposal to increase emergency medical training of dentists based on the six links on survival guide.  At present all dentists are required to be certified in basic life support.  Dentists who provide sedation are already required to have ACLS training.  I believe that any additional training would be redundant and serve no other purpose but provide income for the training companies who are lobbying to have this change passed.  I believe that emergency situations in dental offices are adequately treated with the training that we already have in place and any additional training would not be necessary.   Please use common sense when considering this proposal and vote to no.