Some of the proposed changes are overbroad, impractical, and have no rational basis:

8VAC20-781-480(A)(5) would require that childrens' hands are washed BEFORE playing with water used by more than one child. Given the requirement that childrens' hands should be washed when dirty, what is the point in requiring that their (presumably clean) hands be washed before playing with water?

8VAC20-781-480(D)(1)(a) would require that staff wash their hands BEFORE helping a child use the toilet. First, what is the point of this? Given the existing requirements regarding staff handwashing, there is no point in requiring them to wash their (presumably clean) hands before dealing with a child's toilet issues. Indeed, who among us washes their hands BEFORE they use the bathroom? Second, this change ignores the reality that a child who needs to use the toilet may be in an emergency situation, where they cannot delay answering nature's call. Requiring the child to continue to "hold it" for an unnecessary staff handwashing invites both mess for staff and trauma for the child.

8VAC20-781-480(D)(1)(b), requiring staff to wash their hands BEFORE changing a child's diaper is similarly pointless. There is no rational basis for requiring that staff wash their (again, presumably clean) hands BEFORE dealing with a dirty diaper.