I am submitting this comment anonymously to express concerns and opposition to the proposed fast-track regulation that would mandate all licensed centers to keep stock epinephrine auto-injectors on hand. While I understand and respect the intent to enhance emergency preparedness and safeguard children with severe allergies, this proposal raises several issues that should be addressed before it is implemented.

1. The Fast-Track Process Limits Due Diligence

The decision to move this regulation forward under a fast-track procedure is troubling. Matters involving medical devices, staff responsibilities, and child safety warrant careful review and broad stakeholder input. A rushed process prevents thoughtful consideration of the practical and financial realities faced by childcare centers and could result in uneven or unsafe implementation.

2. Financial Impact on Small and Independent Centers

Many childcare facilities, especially smaller or privately owned ones, operate on narrow margins. The recurring costs of purchasing and replacing epinephrine injectors, combined with storage and training requirements, represent a substantial and ongoing expense. Without designated funding or cost-sharing measures, this rule would impose an unfunded mandate that could strain small centers already struggling to remain compliant with existing regulations.

3. Training, Responsibility, and Liability

The proposal does not clearly define who within a center would be authorized or expected to administer epinephrine in an emergency. Administering medication of this nature carries both medical and legal risks, and not all staff members are trained or comfortable with such responsibility. The regulation should establish specific training protocols and ensure liability protections for those acting in good faith.

4. The Need for an Inclusive and Transparent Approach

No one disputes the importance of protecting children’s health, but such a requirement must be developed collaboratively with input from educators, childcare workers, healthcare professionals, and parents. A more transparent rulemaking process—rather than a fast-tracked decision—would allow for meaningful discussion, realistic planning, and stronger public support.

For these reasons, I respectfully urge the agency to delay or withdraw this proposal and instead pursue a comprehensive, evidence-based approach. The goal of improved emergency readiness is vital, but it should be achieved through well-informed policy, not accelerated regulation.

Thank you for the opportunity to submit these comments and for considering the concerns of those who work within childcare environments and understand the realities of daily operation.