I am submitting this comment as a grandparent who cares deeply about the safety and well-being of children in Virginia’s childcare programs. I am strongly opposed to the fast-tracking of the proposed regulation requiring all child day centers to possess and administer epinephrine.

This proposal places childcare providers in an impossible position. Both state and federal law prohibit giving prescription medication to someone other than the individual it was prescribed for. Yet this amendment would expect childcare staff—who are not medical professionals—to determine when epinephrine should be used and to administer a specific dose. As a grandparent, this deeply concerns me. These same caregivers cannot give a child Benadryl or even apply diaper cream without written parent permission. Epinephrine is far more serious, can remain active in a child’s system for days, and poses significant medical risks if used incorrectly.

The financial burden on daycare programs is also troubling. Centers would be forced to spend $2,000 to $2,400 every year on devices that expire annually. Many childcare programs are already struggling to stay afloat. Adding another costly, unfunded mandate will only make it harder for families to find affordable, safe care for their children and grandchildren.

For the safety of children, the legal protection of staff, and the sustainability of childcare centers, I strongly oppose fast-tracking this regulation. A proposal with such serious implications must go through the full regulatory process, allowing for proper review and public input.