671-210-7 The word "drugs" in this regulation should reflect illegal drugs and  prescription drugs not prescribed to student.

671 - 350-H  Please clarify what is meant by 15 additional hours of annual training.  Does this mean in addition to what is stated in 671-350-A,B,C,D,E,F,G?  Does the word "his" in this regulation need to be changed to be more politically correct?

671 370-A-2 It would be very difficult for my school to be able to accommodate this regulation once it is approved.  There needs to be something to give leeway to programs who already have established instructional area's that do not meet the 50 square feet per person criteria.  This would be a major cost to many programs to update their physical plant to meet this requirement.  There needs to be some sort of grandfather clause that states established classrooms do not need to meet this requirement, however, future renovations or buildings need to.  This would be easy to regulate because our schools are required to submit any program or building changes to the VDOE and it must be approved before it can be done.

671-380-C  I think that 3 tornado drills per year is way too many.  This is a major disruption to school days and may not seem as though it can cause much disturbance, but it can.  I think that tornado drills are appropriate, but we only need to complete one per year.

671-460-G The language in this proposed regulation needs to be changed to be consistent with graduation requirements

671-520-F  Who is ultimately responsible for providing guidance and counseling to students to ensure that a program of studies contributing to the student's academic achievement and meeting graduation requirements are being followed?  It is ultimately the Public School's responsibility to ensure that the IEP is being written accurately and followed, should it not be their responsibility to make sure this guidance and counseling is taking place as well?

671-580 The regulation should be modified to state that virtual courses can only be offered through accredited providers as outlined in VAC 22.1-212.23 and VAC 22.1-253.13:3.

671-620-B This regulation should state that these people need to be notified by the end of the next business or school day. 

671-640  Recommend that this regulation have part A and part B.  Part A would cover students who are placed in time out and part B would cover students who choose to be in time out.  The regulation as it states now goes back and forth between the two instances of using time-out and should be modified to be more clear.  I also believe that time out area's or rooms need to have locks on them, but locks that are spring loaded so they can only remain locked if a staff member is holding it.  There are several reasons for this.  If a students is placed in a time-out room they may still be physically out of control and the continuous use of restraint during this time may cause more injury to staff members and the student being restrained.  If a student is given the opportunity to release some anxiety, stress, or frustration in a setting such as a time-out room there will be less injury.  Also, if there are no locks on the doors or no doors at all students can continuously try to harm staff members by trying to leave the room they are asked to go to.  During this time the intent of the student leaving the room is often unknown and they may try to go hurt someone, flee the building, or want to hurt themselves.  If the student can be contained in an area and monitored for safety there would be less injury to self or others.

671-650-A-1  Restraint and seclusion are listed here in prohibitions, but they aren't prohibited so they should be removed from this section.  It is clearly defined in  671-660-D when seclusion and restraint can be used.

671-660-A-2 If prohibiting prone restraint then supine and side lying restraints should be considered prohibited as well.

671-660-D-1  The language should be modified, in regards to property damage, to state that "causing severe property damage that may result in physical injury to student or