| 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 strongly oppose the Proposed Fast-Track Regulation Requiring Stock Epinephrine Auto-Injectors in Child Day .
As a daycare director and admin for a center with ages 13 months-12 years 11 months I have a few major concerns.
The first concern is what would the liability be that would come along with administering a medication to a child that has never had that medication before as well as knowing which the correct weight would be. Currently we are trained to administer medication that is prescribed by a DR. and that Dr has 1. has determined the child has an allergy and 2. has already taken into account the weight of the child and prescribed the correct dose for that particular child. We are also trained to follow that childs specific allergy action plan. For that plan it states what the child is allergic to and the steps to follow if that child comes into contact or ingests that item. There is no guessing involved. We grab that childs medication bag and action plan and use their epi pen that is weight appropriate and follow the plan. The idea of guessing how much a child weighs and then finding the appropriate epi pen for that weight makes me very nervous not only for myself to navigate but even more so for my staff. We do not have a nurse on staff.
My second concern is the financial burden that would come along with this. As stated above we have children from 13month-12years and 11 months. I am guessing we would need a minimum of 2 at each location and we have 2 locations. I went on google and it states they can cost anywhere from $650 to 700 without insurance. We are already struggling making it week to week meanwhile everything continues to increase. Also epi pens expire so this would be an ongoing cost to the daycares.
I am all for finding ways to protect our children but in the 15 plus years of doing this I have never had a situation where this was needed.