I am writing to oppose the fast-tracking of the proposed amendment requiring every child day center to implement policies for the possession and administration of epinephrine.

This requirement places childcare providers in direct conflict with both state and federal laws, which clearly prohibit administering prescription medication to anyone other than the individual for whom it is prescribed. Expecting daycare administrators—who are not licensed medical professionals—to determine when epinephrine should be used and at what dosage is unsafe and beyond the scope of our training and legal authority. Currently, we cannot administer over-the-counter medications such as Benadryl, nor can we apply basic items like diaper cream, without signed parental permission. Epinephrine is significantly more serious, can remain active in a child’s system for days, and carries far greater risks than the medications we are restricted from using.

Additionally, the financial burden this regulation would place on childcare centers is unrealistic. For my center, annual costs would range from $2,000 to $2,400, and the devices expire every year. Many childcare programs are already operating on thin margins, and this requirement would create added strain without offering a safe or practical solution.

For these reasons—legal concerns, medical risk, and unsustainable cost—I strongly oppose fast-tracking this amended regulation. A requirement of this magnitude should undergo full public consideration, stakeholder input, and careful evaluation before any further action is taken.