The Proposed regulation 8VAC20-781-650 on animals and pets is excessive. Rather than a ban, I would recommend regulations in the form of parental notification, parental permission, or safety policies created by the center.

My 7 year old is very attached to the box turtle at her school and has learned a lot through her interactions with the turtle since she was a toddler. She is very sad at the prospect of the turtle having to be rehomed if this regulation goes into place. While she will be graduating from the school soon, she noted she is sad that other friends would not have the same experience she has had to feed and observe the turtle over the years.

I would further like to comment on 8VAC20-780-340. Supervision of children. I believe that children can be provided more freedom to learn and grow their independence. Child development research shows us that children must explore. Supervising elementary school age children, or preschool children, in the same way as infants are being supervised could harm their developing sense of self efficacy and sense of purpose.

I recommend Virginia adopt this language, which is close to what is recommended by NAEYC: “(1) For preschool children staff must supervise by sight and sound most of the time. Supervision by sound alone is also permissible for short intervals, under five minutes, as long as staff check on children who are out of sight and children are always in a safe area” and “(2) For school-age children doing tasks in a safe environment, they may be out of sight and sound supervision for up to ten minutes provided staff are nearby so they can provide immediate intervention if needed”.

This language would allow educators to scaffold the learning of young children so they can build competency in a safe environment. For preschoolers this is a school readiness skill. For school age children, this proposed language would be consistent with how they are treated in other settings. For example, my other school-aged child that is in public school (but by age would have been subject to this level of supervision until a few months ago) is allowed to walk alone to the nurse's office, a bathroom down the hall from his classroom, or from the front office to his classroom on a different floor. Children are capable and as they grow older should be allowed to move through the safe school environment with less supervision.