I am the mother of 5 children, 2 of which are elementary school aged twins receiving special education services in a self contained classroom. I am also a member of the Special Education Advisory Committee for our school system. I want to clearly state I feel the use of  restraint and seclusion has the potential to be detrimental to the psyche and physical well being of children with and without disabilities. The  parameters used in 8VAC20-750 are concerning, at best, and the language is subjective leaving the guidelines  open to interpretation. During stressful,emergent situations the staff member(s) implementing restraint and seclusion practices should have clearly defined criteria and language to guide them while keeping all of our children and staff safe from harm. The proposed language “to quell a disturbance”,  “while investigating or questioning about violations of the student code of conduct”, and “to maintain order and control” is too vague and can qualify many different scenarios. Furthermore, I have seen no mention of giving students access to alternative means of communication to aid in de-escalating a tense situation. Some students may be non-speaking or not reliably speaking individuals that may have great difficulty understanding/nterpreting situations and the demands placed on them by staff which can lead to restraint and seclusion that may be prevented by improved communication through various modalities such as AAC devices, PECS, etc. VDOE should remember all behavior is communication and this is often the key to avoiding restraint and seclusion. Please consider the child’s perspective. To be restrained or secluded  can cause trauma physically and psychologically with lifelong consequences. 

Julia Ward