To Whom It May Concern:

I am writing as an employee of Little Hearts Daycare to express my concerns and opposition to the proposed fast-track regulation requiring all childcare centers to maintain stock epinephrine auto-injectors on site. While the safety and well-being of every child in our care is our top priority, the way this regulation is being advanced—and the lack of detailed guidance—creates serious challenges for small, self-owned centers like ours.

1. Limited Opportunity for Input

The decision to fast-track this proposal leaves little room for childcare professionals to provide input. As someone who works directly with children every day, I believe our voices are essential in shaping policies that directly impact how we operate and care for our students. Rushing this process prevents thoughtful planning and collaboration with those most affected.

2. Financial and Resource Constraints

Little Hearts Daycare operates on a modest budget, focused primarily on providing quality care and early education. The requirement to purchase and maintain stock epinephrine injectors—especially given their short expiration dates—would impose a significant recurring expense. Without funding or reimbursement, this requirement would likely strain already limited resources that could otherwise support daily operations or educational needs.

3. Training and Liability Concerns for Staff

Administering epinephrine is a medical procedure that requires proper training and confidence. Many childcare workers are not medically certified, and without clear state-supported training or liability protections, staff could face uncertainty and fear of legal consequences, even when acting in good faith during emergencies. Clear standards, oversight, and support must be established before such a regulation can responsibly take effect.

4. Support for Safety—Through Proper Process

We at Little Hearts Daycare absolutely support measures that enhance emergency preparedness and protect children with severe allergies. However, these measures should be developed through a careful, transparent, and inclusive rulemaking process. By engaging childcare workers, medical experts, and administrators, the agency can design a policy that is realistic, effective, and fair for all types of centers.

For these reasons, I respectfully urge the agency to pause or withdraw the fast-tracked regulation and instead pursue a full, public rulemaking process that allows adequate time for training, funding considerations, and professional input.

Thank you for your attention to this matter and for considering the perspective of those who work directly with children every day.

Respectfully submitted,