| Action | Amend regulation to require each family day home provider or other caregiver to be trained in epinephrine administration; notification requirements to parents required |
| Stage | Fast-Track |
| Comment Period | Ended on 12/17/2025 |
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My name is Diuris Quant, and I am a licensed child care provider in Fairfax County, Virginia. I am writing to express my concerns about the proposed requirement that all child care providers maintain stock epinephrine auto-injectors (EpiPens) for emergency use.
I've been a provider for 10+ years and currently have 13 children. My daycare is a small home-based program. While I absolutely support keeping children safe, I have serious concerns about this proposed mandate that I believe need to be addressed before implementation.
FINANCIAL CONCERNS:
The cost of purchasing and maintaining stock EpiPens is a significant burden for my business. As a small provider, I operate on a tight budget with payroll. And this mandate would put us in a compromising situation to have to increase tuition for families.
LACK OF MEDICAL TRAINING:
I am an educator, not a medical professional. I have no medical training beyond basic first aid. I would not feel confident diagnosing anaphylactic shock. I fear making a life-or-death decision incorrectly. I am deeply uncomfortable being placed in a position where I must make complex medical decisions without proper medical expertise.
FEAR OF CAUSING HARM:
I am genuinely worried about accidentally harming a child. What if I inject epinephrine into a child's finger by mistake? What if I give epinephrine to a child who doesn't need it and cause heart problems? What if a child in my care has an underlying heart condition I don't know about? The potential medical complications from incorrect or unnecessary administration are frightening.
DOSAGE UNCERTAINTY:
EpiPens come in different strengths, and I care for children of varying ages and sizes. Without a prescription specific to each child, how do I know the correct dose? I'm concerned about using the wrong strength in an emergency situation.
LIABILITY CONCERNS:
I have contacted my insurance company, and they could not confirm coverage, they indicated my premiums would increase and they could not give me clear answers about liability protection. I cannot afford a lawsuit that could destroy my business. The legal risk alone would have my staff and I stressed out. One incident could end my ability to provide care for families
ALTERNATIVE SOLUTIONS:
I believe there are better approaches that would protect children while being practical for providers:
• Requiring parents of children with known allergies to provide prescribed EpiPens for their specific child
• Improving emergency response times in our area
• Providing training on recognizing allergic reactions and when to call 911
• Creating a voluntary program with state funding and full liability protection
I want to emphasize that I take the safety of children very seriously. However, I respectfully ask that you reconsider this mandate and work with providers to develop solutions that are both effective and practical.
Please delay implementation until these concerns are addressed. Please provide adequate funding and liability protection. Please make this voluntary rather than mandatory.
Thank you for considering my concerns. I appreciate the opportunity to provide input on this important issue.
Kind regards,
Diuris & Javier Quant