I strongly support protecting children from severe allergic reactions; however, I respectfully but firmly oppose this mandate in its current form and urge its removal from the fast-track process.

Requiring non-medical child care staff to assess symptoms and administer a powerful prescription drug to children without a diagnosed allergy significantly increases liability exposure. In an industry already struggling with skyrocketing liability insurance premiums, this added risk could drive premiums even higher, further threatening the financial viability of child care programs across the state.

Additionally, the regulation imposes unfunded costs, estimated at $290 to $850 per device, plus replacements every 12 to 18 months.

Fast-tracking these amendments bypasses the thorough stakeholder engagement, cost-mitigation exploration, and standard rulemaking process that such a resource-intensive mandate requires.

I urge VDOE to withdraw the proposal from fast-track consideration, pursue standard rulemaking, and work collaboratively with stakeholders to develop alternatives that enhance safety without jeopardizing the stability of Virginia’s child care system.