Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Dentistry
 
chapter
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
Action Prescribing opioids for pain management
Stage Emergency/NOIRA
Comment Period Ended on 6/14/2017
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5/16/17  9:39 pm
Commenter: Paul K. Hartmann, DDS

Naloxone requirement
 

Upon my review of the opioid emergency regulations, the requirement to provide a prescription for Naloxone is neither practical nor likely efficatious.  This is intended to give the patient an emergency drug to reverse the additive respiratory depression for patients simultaneouly taking benzodiazopines along with the newly prescribed narcotic analgesic.  It is higly unlikely that it could be used as intended or, for that matter, would be necessary at normal analgesic dosing.  If there occurs an inadvertant overdose, administration of this drug (Naloxone) in untrained hands would be difficult.  Apparently, it can be prepared as a nasal spray, but it does not come this way, and to expect a patient to use it properly and at the appropriate time is unrealistic.  In the hands of a first responder, it can be a lifesaver, but not in this situation.  Please strike this requirement from your emergency regulations.

CommentID: 59198