Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Family Day Homes [8 VAC 20 ‑ 800]
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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12/9/25  1:42 pm
Commenter: Valerie Knight

Opposing Proposed Mandatory Stock Epinephrine Requirement
 

My name is Valerie Knight, and I am a licensed child care provider in Norfolk, 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 for15 years in a home-based program with my son. We care for
children 6 weeks to 5 years old. We are deeply committed to the safety and well-being of every
child in our 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.
It will also have an impact on my household,

LACK OF MEDICAL TRAINING:
I am an educator, not a medical professional. The only medical training I have is first aid. I do
not administer any medication to the children at my daycare. I am deeply uncomfortable being
placed in a position where I must make a complex medical decision without proper medical
training.That could be life or death for someone's child.

FEAR OF CAUSING HARM:
I am genuinely worried about accidentally harming a child. Giving the wrong dose or the wrong
type. Just not knowing anything about the medication could harm the child leading to other
health problems or death. I do not want that in my heart. All of the medical complications from
incorrect or unnecessary administration are too great, just frightening.

DOSAGE UNCERTAINTY:
EpiPens come in different strengths, and I care for children of varying ages and sizes. I’m
concerned about using the wrong strength in an emergency situation,
LIABILITY CONCERN
One incident could end my career,
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.

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

CommentID: 238531