I am writing to express my strong opposition to the proposed mandate requiring all childcare providers to stock epinephrine auto-injectors (EpiPens). As an EpiPen carrier for my own allergies, I fully recognize and support the critical, life-saving nature of epinephrine for anaphylaxis. The proposed mandate creates several complex issues that must be addressed.

A primary concern is the significant and potentially escalating financial burden placed on childcare providers and passed down to families. Second but still extremely important is the health and safety of my child as it relates to wrong dose, improper injection, improper / unsafe storage, etc.   

Additional information on my concerns:

• Requiring all entities to purchase and regularly replace this medication acts as an unfunded mandate. Epinephrine auto-injectors are expensive and have a relatively short shelf life, creating a constant, recurring budget item for procurement and replacement of expired units. 

• This mandate does not address the fact that there are different dosages for different ages and situations. EpiPens are a prescription medication for a reason. This mandate is inappropriate to force prescriptions to be overridden by untrained professionals. 

• A mandate must be accompanied by comprehensive, mandatory training for staff who are expected to administer the drug. This adds substantial costs and time for training, certification, and recurring refreshers. If staff are insufficiently trained, the risk of improper administration and subsequent injury increases.

• For the medication to be truly effective, it must be immediately accessible. However, proper medical protocols require secure storage (locked and temperature-controlled) to prevent theft, tampering, or degradation. 

• Some people are allergic to EpiPen's (specifically the binders in generic brands). If this allergy is unknown and a childcare professional administers the medication, it could be deadly.
• What would this do the liability insurance cost and coverage for childcare providers. Some coverage could be dropped or made so expensive the provider couldn't carry the proper insurance. 

I strongly feel that childcare providers time and money would be better spent on receiving the training to identify an allergic reaction and contact 911 immediately. All dispatched emergency services carry multiple EpiPens and are trained in the appropriate dosage and injection methods. 

Let's leave the life-saving roles to the professionals. This mandate will create an expensive, mandatory burden potentially closing childcare facilities that are not willing to take on the associated risks and/or cost. 

Thank you for your consideration.