Operational responsibilities 

30.G Please eliminate or rewrite all standards relating to undesignated or stock epinephrine. Not only does this conflict with other standards it will be very costly for centers, staff are trained childcare professionals and not medical professionals, this will be a liability issue since standards state no medication can be given without a parent’s consent.

Orientation training

130.D Please include language that those who became directors before the department created prelicensure orientation do not have to complete this training.

Medication administration training

170.C Eliminate this requirement regarding stock epinephrine.  

Indoor and outdoor play areas and equipment

250.J Retain former language. Some sandboxes are too large to cover.

Supervision of children

260.F Define/clarify physical barrier.

Staff-to-children ratio and group size requirements

270.A.5 A group size of 100 children ages 5-12 is too large for 5 staff to supervise.  

270.B.5 Twenty children are too many for one staff person to safely supervise, especially during the summer when ages could range from four years 8 months to 12 years 11 months. 

Daily care and activities for infants

320.B.2 Please change. Do not expose children to hazardous conditions.

Daily care and activities for toddlers, twos, and preschoolers

340.A Please change. Do not expose children to hazardous conditions. 

Parent communication and notification

400.J On injury reports add “if applicable” following future action to prevent reoccurrence. Not all accidents, such as tripping while running outside have a clearly defined method of reoccurrence.

Cribs, cots, rest mats, and beds 

430. H Remove or clarify why cots need to be covered with a nonabsorbent material 

Swimming and wading

450.H.3. Remove or clarify requirement for lifeguard competency and qualifications. Centers do not know how/where a lifeguard at a public pool or lake was trained. 

Hand washing

480.D.1.a. Eliminate the need for staff to wash hands before helping a child use the toilet.  

Requirements for medication administration

510.A Requiring undesignated or stock epinephrine takes away freedom of center to decide on which medication to administer.

510.B. Requiring undesignated or stock epinephrine conflicts with requiring obtaining written parental authorization for medication before a medication is accepted, maintained, or stored at the center 

510.C. Requiring undesignated or stock epinephrine conflicts with medication shall be labeled with the child's name.

510.E  Requiring undesignated or stock epinephrine conflicts with medication shall be given to a child only with written authorization from the parent that has not expired.

510.J Requiring undesignated or stock epinephrine conflicts with other standards in this section.

Prescription medication

520.3. Requiring undesignated or stock epinephrine conflicts with this standard.

Topical skin products

570.D Delete hand soap from this list of products children may not self-administer. Is there documentation that children in childcare have been harmed by using hand soap unattended?  

Nutrition and food services

610.J Delete sanitizing tables after each use since they will be sanitized again before the next use.

610.L Requiring children to remain seated while drinking will eliminate all water fountains. On field trips and outdoor play children will be forced to sit on the ground to drink from a water bottle. Please delete.