I am a pediatrician, public health professional, and child mental health researcher. I also have nearly 5 years of experience as a parent of young children in high-quality early childhood educational settings. I am writing today with several concerns about the proposed new ECE regulations.

Visual media use: Firstly, I am incredibly concerned about the allowance of up to two hours of visual media for toddlers and young children. There is increasing evidence that excessive screen time can have far-reaching neurodevelopmental impacts on outcomes such as language development and mental health years later. On the other hand, I am not aware of any evidence that passive visual media, i.e., screen time, is at all helpful in early child development. Regulators should consider the fact that many young children view more than two hours (the maximum "allowable" amount, according to the American Academy of Pediatrics) at home; adding another two hours at school would likely put children at significant risk of the negative outcomes of excessive screen time, with no benefits.

This is also an equity issue, as excessive screen time is not equally distributed across families. Children from lower socio-economic backgrounds or more stressful households are at higher risk of excessive screen time, so this regulation may only exacerbate that disparity. As a parent, I would be extremely concerned if my young child were receiving any screen time in an ECE setting, and I think parents deserve to know if screen time is being used in lieu of high-quality education. Here are just a few of the recent studies that have made headlines related to these issues:

Excessive screen time could limit vocabulary of toddlers, experts warn | Children | The Guardian

Increased screen time linked to aggression, anxiety, low self-esteem in kids, study finds - ABC News

MRIs Show Screen Time Linked To Lower Brain Development In Preschoolers - CBS Baltimore

Screen Time, Sociodemographic Factors, and Psychological Well-Being Among Young Children | Pediatrics | JAMA Network Open | JAMA Network

Supervision requirements: I am also concerned about the requirement that all children under 10 be constantly supervised by sight and sound without barriers. While seemingly a protective measure, this is practically challenging and developmentally inappropriate. A nine-year-old child can be trusted to fetch an item from another room, just as they might do at home, whereas a two-year-old may not be able to safely complete this task. Arguably, allowing some independence of movement among older children is critical to their developing confidence and sense of self-efficacy, which have positive impacts on long-term mental health.

Furthermore, barriers like baby gates and Dutch doors are critical daycare safety features that allow for easy movement while preventing the youngest children from entering or exiting spaces without an adult caregiver. These childproof barriers also prevent older children from disturbing younger children at rest. While these might technically be "barriers" prohibited in the new regulations, they are critical safety measures that allow many daycares to adequately serve children from age zero up to 8+ years.

Separate outdoor play spaces for infants/toddlers and preschool/school-aged children: Many daycares struggle with finding time for all children to access outdoor spaces. We know that daily outdoor time is essential to children's health, with benefits as far-reaching as reduced childhood obesity, decreased risk of myopia, improved mental and behavior health, improved sleep, improved immune system function, improved long-term cardiovascular health, and much more that cannot be captured in this brief comment. Furthermore, mixed age outdoor play supported by age-appropriate teacher ratios empowers children to negotiate others' needs with empathy and to learn how to interact with people of different ages and developmental abilities.

In practice, school-aged children are unlikely to spend significant amounts of time playing with infants, and therefore it is hard to imagine significant danger that could arise from outdoor space sharing across age groups. Loss of outdoor time can negatively impact adults' moods, cognitive function, immune system health, and more. As a parent, I feel it is critical for all children AND teachers to have sufficient daily outdoor time, and I trust teachers to keep all children safe when multiple age groups share space (as they would on a public playground, for instance). It is unclear what problem this new regulation is attempting to solve, but I am concerned that it could have unintended consequences for the health and well-being of all members of daycare communities.

Thanks very much for your attention.

Sincerely,

Irène Mathieu, MD, MPH