Thank you for this opportunity to comment on the Digital Devices in the Classroom Health and Safety Guidelines. I am a digital wellness instructor, health journalist, Commonwealth resident, and former Fairfax County Commissioner (Hunter Mill district). In 2020, I attended hearings on HB 817 and testified in support.  

The guidelines and infographic are an important start, but major improvement is needed. In current form, they do not correspond directly with the law, especially pertaining to the stipulations: 

1. Digital device use for different age ranges and developmental levels
2. Amount of time spent on digital devices in the classroom

Regarding the written Guidelines (pp. 1-11)

The written section of the Guidelines contains some useful guidance, but as such is disorganized, repetitious and needs additional content. (see below)

More work is needed to make the document more user-friendly, such as adding internal links to recommended resources, or—better yet—clearly summarizing the information.

Since these guidelines are meant for teachers and other school staff, it may not be appropriate to include information for parents. However, if information for parents is included, it should be clearly delineated and separate from information meant for teachers.  

Regarding the Guidelines Infographic:

These guidelines are to protect students, not devices. Therefore, the first paragraph of page 1 should be modified to say “health and safety best practice guidelines for the effective integration of digital devices in public schools” to “to develop and distribute health and safety best practice guidelines for student use of digital devices in public schools,” as is stated in the written guidelines.

All messaging should directly and specifically correspond to the written guidelines.

In current form, content is disorganized and should be re-arranged for maximum impact and at-a-glance understanding.

For instance, since the Guidelines protect student safety and health around digital devices, it is appropriate that sections on Screen Time & Break Frequency/Ergonomics & Posture appear on the front page. Segments under those headings also need to be reorganized and clarified to avoid repetition and make concepts easier to understand.  Note: I can provide detailed edits upon request.  

For greatest instructional impact, graphics should depict specific best practices, such as:

1. Ideal ergonomic setup, with child seated feet on floor in a chair with a back with arms in proper position.
2. Child rubbing eyes to indicate it’s time to take a break from staring at the screen
3. Child looking up from screen to illustrate 20-20-20 rule
4. Child holding mobile device in correct position, i.e. holding a tablet with arms in the shape of an “L” and not a “V.” (much easier to understand than saying 100 or 110 degree angle)
5. Child doing physical activity such as a jumping jacks next to desk to illustrate activity break
6. Child depicted playing outside to illustrate outdoor exercise break
7. Chart of daily screen time recommendations per grade level (less in younger grades, etc.)  

Additional content needed in the Guidelines:

1. Digital device usage guidance per student grade level, age span, or developmental level.
2. Recommended duration of student device usage by grade level, age span, or developmental level. (Many of the physical ailments described in the guidelines are caused by children spending too much time using devices.) 
3. Reasons children need physical activity, especially in the outdoors.
4. Physical signs to watch for that indicate a child is experiencing wrist strain. Strain should not be allowed to persist to the point that a student is wearing a wrist brace or taking medicine.
5. How to measure humidity in the classroom such that there is sufficient moisture in the air for optimum eye health. It shouldn’t be up to students to “blink more” or “blink harder.” Those symptoms happen when children are already over using screens and not taking breaks.
6. Instruction on how to measure WiFi levels in the classroom, students’ safe physical proximity to WiFi emitters (such as WiFi hot spots), and safe usage of digital devices that emit RF energy (example: do no place devices connected to WiFi directly on your body.) 

Guidelines should indicate where they can be added to existing curriculum, such in Physical Education or  Health.

Finally, digital wellness communicators such as myself and child advocates knowledgeable in this area should be part of the Guidelines refinement process.