| 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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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.