Let’s clean up things that are unnecessary in these standards. The majority of the standards called out below are not a big deal, they are not bad, they are just already covered by other sections. If we want to have a functional regulatory framework we could clean up these things and make this document much better.

1. Stock epinephrine is medication.

REMOVE - 8VAC20-781-30 G 3. Undesignated or stock epinephrine is stored in a locked or inaccessible container or area in the center.

It is already covered in 8VAC20-781-540A Storage of medication

2. Electrical details are duplicative.

REMOVE - 8VAC20-781-210 Building maintenance B 7, 8, and 14

• 7. Electrical cords are not spliced, deteriorated, or damaged, and unsecured electrical cords are inaccessible to children preschool age and younger.

• 8. Extension cords have the seal of a nationally recognized testing laboratory; shall not be overloaded, and shall not be placed through doorways, under carpeting, or across water source areas.

• 14. Hazardous mechanical or electrical equipment are inaccessible to children.

Section A more than covers all of those details and child care centers receive fire inspections as well as child care licensing inspections. This is not unclear without these details.

3. All equipment is already supposed to be age appropriate.

REMOVE - 8VAC20-781-250 B. Indoor and outdoor playground and climbing equipment shall be age appropriate for the children using it.

Section 8VAC20-781-420 already states B. Materials and equipment shall be available and shall be age and stage appropriate for the children and shall include an adequate supply, as appropriate for each age group, of arts and crafts materials, texture materials, construction materials, music and sound materials, books, social living equipment, and manipulative equipment.

4. Climbing equipment can’t be installed over concrete because it must be over protective surfacing.

REMOVE - 8VAC20-781-250 G. Climbing equipment and swings shall not be installed over asphalt or concrete unless the asphalt or concrete is: plus sub items and table (all of G can be removed)

Section 8VAC20-781-250 C already requires protective surfacing. The way this is written with G and C is also confusing. It seems like C could simply say, properly installed unitary surfacing or loose fill surfacing.

5. It would be clearest if things were not duplicative.

REMOVE - 8VAC20-781-250 S. When inflatable equipment is used, the equipment shall be assembled, maintained, and used in accordance with the manufacturer’s instructions.

Section 8VAC20-781-420 A reads furnishings, equipment, and materials shall be (i) of an appropriate size for the child using it and (ii) used in accordance with the manufacturer’s instructions. Which would include inflatable equipment.

6. Educational programming is excluded from visual media hours already.

REMOVE 8VAC20-781-310 D. Requirements in subdivision 3 of subsection C of this section do not apply to school-age children who attend educational programming that incorporates technology into curriculum learning activities.

Section 8VAC20-781-250 C3 already allows for educational or curriculum based activities to be excluded from the total hours.

7. The new language made the other language irrelevant.

REMOVE - 8VAC20-781-610 E. In environments of 80°F or above, attention shall be given to the fluid needs of children at regular intervals. Children in such environments shall be encouraged to drink water as outlined in subsection D of this section.

Sections 8VAC20-781-610 D already states Drinking water shall be offered at regular intervals to children.

8. Not using powered milk is already a part of the USDA guidelines.

REMOVE - 8VAC20-781-610 F. When centers choose to provide meals or snacks, the following shall apply: 5. Powdered milk shall not be used except for cooking.

Section 8VAC20-781-610 F 1. Already states that “Centers shall follow the most recent, age-appropriate nutritional requirements of the Child and Adult Care Food Program administered by the United States Department of Agriculture (USDA).” Which doesn’t allow powered milk except for cooking.

9. The food standards are repetitive.

REMOVE - 8VAC20-781-610 M. Food and beverages shall be prepared, served, stored, and transported in a sanitary manner.

It is required by 8VAC20-781-610 I. “Contaminated or spoiled food shall not be served to children.” which is sufficient for ensuring food safety.

10. New standards around nap mats makes the evening standard unnecessary.

REMOVE - 8VAC20-781-660 A. For evening care, beds with mattresses or cots with at least one inch of dense padding shall be used by children who sleep longer than two hours and are not required to sleep in cribs.

Nap mats are now required by 8VAC20-781-430 I to have one inch of cushioning.