| Action | Amend regulation to require each child day center to implement policies for the possession and administration of epinephrine |
| Stage | Fast-Track |
| Comment Period | Ended on 12/17/2025 |
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I am writing in opposition to an expedited process for section Q related to child care centers implementing policies for the possession and administration of undesignated or stock epinephrine. I understand that the proposed regulation follows the recently enacted law. However, this is a controversial issue where providers are charged with purchasing stock epinephrine without reimbursement and are also charged to ensure that an authorized person trained in the administration and dosage is onsite to administer the drug in emergencies. Child care centers do not regularly have a nurse at the center. I am requesting that the normal NOIRA process be followed to ensure that all aspects of this proposed regulation can be addressed in an effective manner. For example, how are staff trained? Where are they trained? Is there a cost to the training? Will more than one staff at a center require the training so that someone is always onsite trained in the administration of the drug? How is the dosage determined? Who determines the dosage? How much of the epinephrine needs to be purchased to ensure a sufficient supply is on site and how is it stored (e.g., is there an expiration date associated with the drug)? These are serious issues for the safety of children. It seems to me that fast tracking a complicated and controversial requirement, which could result in unintended harm to children should be considered in accordance with the regular process. At worst, fast tracking this requirement could result in a costly endeavor for providers while potentially (if not administered correctly) harming children. This would be ironic since it appears that the intent of the legislation is to promote the safety of children. The regular process should allow for consideration and resolution of how this requirement can be implemented safely. Guidance for centers on the amount to be purchased is also needed, particularly because centers will not be reimbursed (unless future legislation is passed to cover the cost).