The Autistic Self Advocacy Network, a grassroots organization of people on the autism spectrum, supports a complete ban on prone restraint, with no exceptions. No child should be restrained because of behaviors that are part of a disability. In addition, we support positive behavioral supports rather than the use of restraints. [Update, July 2009: ASAN has revised its policy and does not advocate the use of positive behavioral support (PBS) programs.]
Many important areas are not addressed in the proposed rule. The rule as promulgated provides no clarification on use of prone restraint, no clarification of the use of restraints and seclusion for behaviors that are often specific to the student’s disability, such as property destruction which was mentioned by one parent here. The term “reasonable” is too vague.
The word “should” needs to be replaced by the word “will,” otherwise the regulations become meaningless. We strongly recommend notification of parents for any disciplinary measure. We support the inclusion of language that would hold schools accountable for violations of the regulations. First and foremost the regulations need to be clarified. Too much is left to the discretion of school personnel.
We urge training of all personnel and monitoring of all interventions used with students. We oppose corporal punishment and seclusion techniques. The rule needs to be standardized across the state rather than left up to the discretion of local school boards.
Paula C. Durbin-Westby
The Autistic Self Advocacy Network