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Cut and paste this email and personalize it and send it to

the Department of Education.

K. Lipson, JD

Director, Parent Leadership Support Project

The Georgia Advocacy Office

One Decatur Town Center

150 E. Ponce de Leon Ave., Suite 430

Decatur, GA 30030

(404) 885- 1234 or 1 (800) 537- 2329 (voice or TDD)

llipson@...

www.thegao.org

June

, 2010

VIA

E-Mail to ameyer@... and US Mail

Allan

Meyer

Assistant Director, Policy

Georgia

Department of Education

2053 Twin Towers East

205 Hill Jr. Drive, SE

Atlanta, GA 30334

RE: Rule

160-5-1-.35 Seclusion and Restraint

Dear Mr.

Meyer:

I am

writing to provide feedback regarding the Rule 160-5-1-.35 “Seclusion and

Restraint for all Students.” I appreciate the opportunity to

comment on the rule and to be involved in the development of the rule. I

care about this issue because…

As

such, I am committed to the development of a rule that supports schools to

educate children in safe and positive environments that foster learning and

growth.

I

support the Department’s decision to address the issue of restraint and

seclusion through the development of a rule. In particular, I support

GDOE’s prohibition on seclusion, prone restraint, mechanical restraint,

and chemical restraint. The comments below are designed to impose

significant limitations on the use of physical restraint and to build

safeguards into the process by which school personnel use restraint on a

student.

(Please

choose one, all, or none of the following bulleted points. Please add any

comments you wish to share with the Department of Education).

·

Physical

restraint, an inherently dangerous practice, should only be used in

situations of risk of serious bodily injury and is only justified based on

actual behavior of the student in the time of emergency.

·

Physical

restraint may never be used for disciplinary purpose, convenience of

faculty or staff, or as a substitute for appropriate positive teaching

strategies, techniques, and supports.

·

Restraint

is prohibited to those situations when less intrusive efforts are not effective

and there is danger of serious bodily injury to self or to others.

·

Schools

should use Positive Behavior Supports as an intervention for students with

disruptive or challenging behaviors. Early identification and

intervention are key to effective utilization.

·

Physical

restraint should only be applied to students by school personnel who have been

trained and certified in a State-approved training program consisting of

instruction not only in applying restraint, but also in de-escalation

strategies and problem solving techniques.

·

School

systems should be required to document and report each specific instance of

physical restraint on a student in their school.

·

Behavioral

support for students must promote the right of all students to be treated with dignity

and to be educated in a safe environment.

·

Data

should be collected using uniform methodology and regularly reviewed at the

local, district, and state level to ensure system wide compliance and

transparency.

·

Data

results and comparisons should be made readily available to the Department of

Education, parents and other stakeholders in order to promote opportunities for

training, education, and development.

·

Standards

of data collection concerning the use of physical restraint should be uniform

across all districts. Districts with reduced incidences in accordance

with set standards should be recognized for achievement and highlighted for

training opportunities; conversely, districts who fail to decrease and/or

exhibit an increase in incidences of restraint and seclusion should be subject

to further investigation, probation, and appropriate re-training.

·

Individual

incident counts should be an integral facet of data collection in order to

accurately trend schools and districts effectively and/or excessively utilizing

the approved practices of restraint. The specific nature of this

collection will serve to promote accountability and awareness for

administrators, facilitators, and parents.

Again,

thank you for the opportunity to provide commentary on this initiated

rule. We respectfully request the School Board members resend the current

rule and strengthen the accountability and enforcement provisions and

reinitiate the rule in the June 2010 meeting to continue this important

work. I look forward to continuing to work with you to help keep the

children of Georgia safe.

Sincerely,

Family

Doe

cc:

O'Hara

Associate Superintendent

Innovative Instruction

1752 Twin Towers East

205 Hill Jr. Drive, SE

Atlanta, GA 30334

nohara@...

Debbie

Gay

Director, Special Education Services

1870 Twin Towers East

205 Hill Jr. Drive, SE

Atlanta, GA 30334

DGay@...

Kim Hartsell

Director, Special Education Supports

1870 Twin Towers East

205 Hill Jr. Drive, SE

Atlanta, GA 30334

khartsell@...

Ruby

Executive

Director

Georgia

Advocacy Office

Safe

Schools Initiative

150 E.

Ponce de Leon Ave., Suite 430

Decatur,

Georgia 30030

info@...