Thank you for the opportunity to comment on the proposed fast-track regulation mandating that child day centers possess, store, and permit administration of stock epinephrine auto-injectors.

As a licensed childcare provider, 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.

Existing regulations already protect children with known allergies through required individualized health care plans, parent-provided epinephrine, staff training, and physician-authorized administration.

Asking non-medical childcare 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 new risk will drive premiums even higher — further threatening the financial viability of ALL childcare programs.

The costs of stockpiling Epi Pens for all the sizes needed in childcare facility running ages 6 weeks to 12 yrs and then replacing them ($290–$850 per device + frequent replacements every 12–18 months), as needed would be beyond the means of any facility. This would divert scarce resources from staff wages, facility needs, and serving low-income families.

It inappropriately shifts medical decision-making and pharmacological responsibilities onto early childhood educators who lack clinical training and oversight (unlike K-12 settings with school nurses).

Current protocols — parent/physician-provided epinephrine for known allergies + immediate 911 activation for any suspected reaction — are proven, targeted, and sufficient. Voluntary programs, subsidies, or enhanced recognition training would achieve the same goal without punishing providers.

This proposal is highly controversial due to its significant cost, liability, insurance-premium, and equity implications. Fast-tracking bypasses the thorough stakeholder engagement, cost-mitigation exploration, and standard rulemaking process that such a resource-intensive mandate requires. Rushing forward risks program closures and reduced access in underserved communities.

I urge you to withdraw this proposal from fast-track consideration, pursue standard rulemaking, and work collaboratively with childcare providers, insurers, and medical experts to develop sustainable, fully funded, or voluntary alternatives that enhance safety without jeopardizing the stability of Virginia’s childcare system.

I welcome continued dialogue and can be reached at amy@honeytreeelc.com.

Thank you for your consideration.

Sincerely,  
Amy Ralston 
HoneyTree ELC's
Roanoke, VA