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).