My name is Soraya Fedayi, and I am a licensed child care provider in Gainesville, Virginia. I am writing to express my concerns about the proposed requirement that all child care facilities maintain stock epinephrine auto-injectors (EpiPens) for emergency use.

I have been providing child care for 14 years and currently care for 11 children ranging in age from one to three years old. My facility is a small home-based program. I am deeply committed to the safety and well-being of every child in my care.

While I absolutely support keeping children safe, I have serious concerns about this proposed mandate that I believe need to be addressed before implementation.

FINANCIAL CONCERNS:

The cost of purchasing and maintaining stock EpiPens is a significant burden for my business. As a small provider, I operate on a tight budget and I would have no choice but to increase tuition  for each child. 

LACK OF MEDICAL TRAINING:

I am an educator, not a medical professional. I have no medical training beyond basic first aid and I would not feel confident diagnosing anaphylactic shock. I fear making a life-or-death decision incorrectly and I am deeply uncomfortable being placed in a position where I must make complex medical decisions without proper medical expertise.

FEAR OF CAUSING HARM:

I am genuinely worried about accidentally harming a child. What if I inject epinephrine into a child's finger by mistake? What if I give epinephrine to a child who doesn't need it and cause heart problems? What if a child in my care has an underlying heart condition I don't know about? The potential medical complications from incorrect or unnecessary administration are frightening.

DOSAGE UNCERTAINTY:

EpiPens come in different strengths, and I care for children of varying ages and sizes. Without a prescription specific to each child, how do I know the correct dose? I'm concerned about using the wrong strength in an emergency situation. 

SUGGEST ALTERNATIVES

I believe there are better approaches that would protect children while being practical for providers:

• Requiring parents of children with known allergies to provide prescribed EpiPens for their specific child

• Improving emergency response times in our area

• Providing training on recognizing allergic reactions and when to call 911

• Creating a voluntary program with state funding and full liability protection

I want to emphasize that I take the safety of children very seriously . However, I respectfully ask that you reconsider this mandate and work with providers to develop solutions that are both effective and practical.

Please make this voluntary rather than mandatory. 

Thank you for considering my concerns. I am happy to discuss this further and appreciate the opportunity to provide input on this important issue.