| Action | Amend regulation to require each family day home provider or other caregiver to be trained in epinephrine administration; notification requirements to parents required |
| Stage | Fast-Track |
| Comment Period | Ended on 12/17/2025 |
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As a medical professional and a parent in Northern Virginia, I am very concerned about the proposed law requiring childcare providers to carry and administer epinephrine to children they *believe* may be experiencing anaphylaxis.
While I understand the intention is to protect children with severe allergies, this proposal raises significant safety and practical concerns:
1. Medical Risk: Administering epinephrine carries serious risks if given unnecessarily or incorrectly. Non-medical personnel are not trained to assess whether a child is truly in anaphylactic shock, and misuse could result in severe complications, including hypertensive crisis, arrhythmias, or other life-threatening outcomes.
2. Training Limitations: A single demonstration or two on using an auto-injector does not prepare someone to recognize anaphylaxis or manage complications that may arise from inappropriate use. It is not a course on anatomy and physiology and does not prepare the provider to respond if an adverse even occurs.
3. Financial Burden: This would shift additional costs onto already overburdened childcare providers and families in Virginia, where childcare costs are already among the highest in the country.
4. Liability Concerns: Providers may face legal exposure if an epinephrine injection causes harm, despite good intentions.
I urge lawmakers to consider alternatives that prioritize both safety and practicality, such as:
-Allowing only medically trained personnel to administer epinephrine.
-Requiring individualized emergency action plans for children with known severe allergies.
-Providing funding or support for professional medical oversight in childcare settings.
While protecting children from anaphylaxis is critically important, this proposal could unintentionally put children at risk and impose unsustainable costs on families and providers.
Thank you for considering these concerns.
-Concerned mom, EMS provider and RN
If you want, I can also help you **condense this into a shorter, punchy version** that is more likely to be read and noticed on the public comment board while keeping the key points. Do you want me to do that?