I am submitting this comment as a childcare staff member who works directly with young children every day. I strongly oppose the fast-tracking of the proposed regulation requiring all child day centers to possess and administer epinephrine.

This amendment would put staff like me in a legally and medically risky position. Under state and federal law, we cannot administer prescription medication to anyone other than the person it was prescribed for. Yet this regulation would require us—non-medical personnel—to determine when epinephrine is needed and to deliver the correct dosage. Currently, we cannot give a child Benadryl or even apply diaper cream without written parental authorization. Expecting us to administer epinephrine, which carries significant risks and can affect a child’s system for days, is far beyond what our training and legal guidelines allow.

There is also a serious financial impact on the centers we work for. Many programs are already operating on tight budgets, and requiring epinephrine devices would add $2,000 to $2,400 in annual costs—for products that expire every year. These added expenses strain already-limited resources and ultimately affect the quality and availability of care for families.

For the safety of the children we serve, the legal protection of staff, and the financial stability of childcare programs, I strongly oppose fast-tracking this regulation. A change of this magnitude deserves full review and input from those directly impacted.