I am submitting this comment anonymously to express opposition to the proposed fast-track regulation that would require all licensed childcare centers to maintain stock epinephrine auto-injectors on site. While I fully support protecting children with severe allergies and ensuring emergency preparedness, I believe this proposal—especially under a fast-tracked process—raises several practical and ethical concerns that must be addressed before implementation.

1. Inadequate Opportunity for Public Input

The fast-track process limits meaningful participation from those directly affected by the rule. Childcare providers, staff members, and families deserve the opportunity to review, question, and contribute to a regulation that impacts daily operations and child safety procedures. Skipping that step risks introducing policies that are not feasible in practice.

2. Financial and Operational Burden

The cost of purchasing and maintaining epinephrine auto-injectors, which expire frequently, presents a significant financial burden, particularly for small or independently owned centers. Many facilities operate with limited funding and no additional financial support for new mandates. Without clear provisions for reimbursement or assistance, this rule would create an unfunded obligation that small centers cannot easily meet.

3. Liability and Training Challenges

Administering epinephrine is a medical act that requires clear training, confidence, and legal protection. Many staff members in childcare settings are not licensed medical personnel, and the proposal does not specify who would be responsible for administration, documentation, or liability in case of complications. Implementing a medical requirement without addressing these details could expose staff and centers to unnecessary risk.

4. Need for a Careful and Transparent Approach

Policies concerning children’s health and safety should be enacted through a measured and inclusive process. Rushing this regulation through a fast-track system undermines public trust and may result in confusion or noncompliance. A collaborative approach that includes medical professionals, childcare providers, and parents would ensure a more balanced and sustainable policy.

In summary, while the intent behind this proposal is understandable, its current form and expedited process are deeply flawed. I urge the agency to pause or withdraw the fast-track regulation and instead engage in a full, transparent rulemaking process that considers safety, practicality, and equity.

Thank you for your attention and for considering the perspective of those who work directly with or on behalf of children every day.