Thank you for the opportunity to speak. I want to begin by acknowledging the importance of protecting children during medical emergencies. Those of us who work closely with young children care deeply about their safety and well-being, and we share the same goal: ensuring every child has the best chance of surviving an anaphylactic reaction.

However, I respectfully oppose the proposed amendments to the Child Care Program regulation (8VAC20-790) that would require childcare programs to stock epinephrine and assign non-medical personnel the responsibility of determining and administering weight-based doses. While the intention behind this proposal is understandable, it introduces serious risks—both to children and to the educators tasked with carrying out these high-stakes responsibilities.

1. Safety Risks for Children When Medical Judgment Is Placed on Non-Medical Personnel

Childcare providers are trained, compassionate professionals whose expertise lies in nurturing children, supporting development, and maintaining safe environments—not practicing emergency medicine.

Requiring staff to diagnose a potential anaphylactic episode and determine if epinephrine is necessary places them in an impossible position. Symptoms of anaphylaxis often mimic other conditions, and administering epinephrine to a child who does not need it can cause significant medical complications. Even with MAT training, staff are not—and cannot be—equipped with the clinical judgment needed to reliably differentiate between these conditions under the pressure of an emergency.

Additionally, MAT training cannot mirror the skill, confidence, or decision-making of licensed medical professionals. High staff turnover means providers must constantly retrain new staff. And in the stress of a critical moment, even small errors—injecting into the wrong site, hesitating, or misinterpreting symptoms—could lead to harmful outcomes.

2. The Serious Dangers of Requiring Non-Medically Trained Staff to Determine Weight-Based Doses

The proposal’s requirement to maintain “an appropriate weight-based dosage of epinephrine” introduces another layer of significant risk.

Children’s weights vary greatly and change rapidly. Determining the correct dose is not simple—it requires accurate, current weights, clinical knowledge, and medical oversight. Expecting teachers to estimate weights, calculate dosages, or maintain multiple stock doses is unsafe and unfair.

A dose meant for an adult administered to a small child—or a dose too low to help a larger child—can have life-altering or fatal consequences. These decisions should remain strictly in the hands of medical professionals and parents in consultation with their child’s physician. Asking childcare providers to assume this responsibility effectively requires them to act as pharmacists and emergency clinicians, roles far outside their training and legal scope.

3. The Emotional and Psychological Toll on Childcare Providers

There is also a human element that must be acknowledged.

Childcare providers dedicate their lives to caring for young children. If a provider were required to administer epinephrine without proper medical training and something went wrong—even with the best intentions—the emotional impact would be devastating.

We must consider:

• The lifelong trauma a teacher would carry if a child were harmed or died because of an incorrect administration.

• The ripple effect this trauma could have on the teacher’s mental health, family, and career.

• The moral burden placed on individuals who simply want to nurture and protect children, not perform emergency medical interventions beyond their expertise.

We cannot overlook the psychological cost of transferring complex medical responsibilities onto educators who did not choose this path and are not prepared to bear its consequences.

Conclusion

Protecting children from anaphylaxis is critically important, but this proposal shifts complicated medical decision-making from trained professionals to well-meaning, untrained childcare staff—creating risks that may outweigh the intended safety benefits.

A safer, more appropriate approach would emphasize:

• Immediate activation of emergency medical services (911),

• Clear communication procedures between families and providers, and

• Ensuring that children with known allergies have physician-prescribed, child-specific medication plans on site.

We all want what is best for children. I respectfully urge you to reconsider these regulations and pursue solutions that protect children without placing childcare providers in medically and emotionally unsafe positions.

Thank you for allowing the opportunity to share my view.