With this mandate, the burden of expense falls on the non-profit center who already struggles to meet the ever growing costs of child care. For a program that cares for children ages birth to five-years-old, the requirement of having epi-pens designated by weight would mean that the center must have multiple epi-pens on hand for the multiple ages and sizes of the children in the center. 

• "To implement the revised regulations, licensed child day centers and unlicensed subsidy center-based programs would be required to obtain appropriate weight-based dosage of stock or undesignated epinephrine based upon market cost, which ranges from $290-$850 per device at this time."

Assuming the weight classifications would require the center to maintain three epi-pens at a time for each of the three weight groups that are cared for in the center... this could mean annual costs of $870-$2,550. This expense does not cover any training, certification or storage expenses, nor does it include the potential need for replacing an epi-pen that has been used. 

In a childcare setting, great lengths are taken to reduce the risk of allergic reactions, however it is the responsibility of the parent to track allergies and inform the center of such allergies. It should be the responsibility of the parent to procure and manage epi-pens as needed, including replacing them annually. 

I oppose this mandate and the fast-track implementation.