February 13th, 2019

Chris Hutchinson
Mississippi State Board of Dental Examiners
Suite 100
600 Amite St
Jackson, MS 39201

Re: Public Comment on Amendment to Regulation 29

Thank you for allowing me time to speak at the MSBDE a

few months ago. As you may recall I am the current
President of the Mississippi Chapter of the American
Academy of Pediatrics. We are an organization of 300+
members representing all areas of our state, composed
of General Pediatricians, Pediatric Subspecialists,
academicians, community physicians and allied health
providers. We are an advocacy organization, with our
primary focus on the health and well-being of children, a
group who often lacks a voice in policy discussions.

There has been movement toward providing moderate

and deep sedation in the ofce setting on pediatric
patients.

This frightens me.

The board, of course, should continue its work in

assuring the proper credentials and training of those
applying for anesthesia permits. However there is
inadequate scrutiny in determining whether or not this
level of sedation should even be performed in the ofce.
Without scrutiny and oversight there will be harm -
which can be prevented by sound policy making.

In short, the board should be doing more to protect

patients.

At the last meeting I enumerated several reasons why I

make this assertion. To summarize: Pediatric patients all
respond diferently to anesthesia - and they certainly
respond diferently than adults. The depth of sedation
can change from minute to minute. The airway is
narrower, the chest wall more compliant, and the lung
parenchyma is more reactive.

Working in my local hospital, I’ve had calls to care for

children who during anesthesia developed
laryngospasm, asthma exacerbations, pneumonia, low
oxygen saturations, dangerously low heart rates,
persistent altered levels of consciousness, etc.

Imagine the horror of a parent who learns one of these

complications has occurred in an ofce and 9-1-1 had to
be called for transportation to an emergency room. It’s
not a question of if, but of when.

Moderate and deep sedation should not be performed in

an outpatient clinic, but rather in a hospital, ambulatory
surgery center or equivalent. The operating dentist
should not be the same as the person administering the
anesthesia. This person’s sole focus should be on
monitoring the patient. There should be medical backup
available in the case of the inevitable complication. The
equipment used in the procedure should be stationary
and subject to regular inspection and quality control.

Most people won’t be aware of these discussions when

they take their child to the dentist for restorative
work. They will trust that if the procedure is
recommended by a professional at a clinic, it must be
safe. We want to work with you to ensure that trust is
not betrayed.

Sincerely,

John W. Gaudet, MD, FAAP

Hattiesburg, MS
President, Mississippi Chapter of the American Academy
of Pediatrics
CC
OLRC
Governor Bryant
Secretary of State Delbert Hosemann
Attorney General Jim Hood