I am the director of a licensed center located in Bridgewater, VA. I have serious concerns regarding the potential regulation to store weight-based epinephrine at the center and administer "as needed." I am a MAT certified staff member, however I am uncomfortable with the notion that any staff member would be in a position to make medical decisions (aka deciding if a child is experiencing anaphylactic shock to administer the epinephrine). I am also concerned about how we are to know a child's weight in a moment of emergency. We have a 2 year old in our program that weights around 48 pounds but I would not know that weight for every child and have concerns for children that are outside of the "normal weight category" for their age. I do not have a nurse on staff (or medically trained staff member) and this feels like a huge risk of liability to make judgement calls of when to give epinephrine to a child that has never been administered the medication before without doctor's instructions. Also the cost to have enough weight based pens available is a cost to our company we are not prepared to take on. We serve children infant age through 12 years old. I am not entirely sure, but I imagine we would have to have 4-6 epinephrine pens on hand to serve those varied weights. These would expire annually (potentially) and would create an ongoing cost to our company. As a center Director, I am very opposed to such regulations and would create a system which requires educators to make medical decisions and take on a liability that I am not comfortable with.