I would like to start by thanking the VDOE for taking the time to make this a priority.  The standards have been conflicting between licensing and subsidy for years and some of the changes didn't make sense.

Thank you for changing the date of tb screenings to 90 days prior to hire.  With the timing of background checks, sometimes that 30 days fell outside of the time between getting fingerprinted and getting hired, making scheduling an appointment hard.  Especially in a rural location like the Northern Neck.

Also a huge shout out to adding cleaning tables & high chairs before and after each use as it seemed ridiculous and gross that it was previously only required to sanitize every time and clean once daily.

A few things that I think need clarification or corrections are:

In the section below, there is no definition of sleep adaptive equipment

8VAC20-781-340 Resting and sleeping infants

D. The licensee shall ensure that staff shall not use sleep adaptive equipment unless otherwise directed in a written, signed statement by the child’s physician or physician’s designee.

In the section below, the use of a swaddling method for infants or sleep sacks is unclear.

8VAC20-781-440 Cribs, cots, rest mats, and beds

O. No soft objects or loose bedding shall be used with infants under 12 months when sleeping or resting including pillows, blankets, quilts, comforters, sheepskins, bumper pads, or stuffed toys.

In the section below, there was previously no requirement to document the application of sunscreen.  I was hoping that the same would be possible for bug spray- as it is applied regularly like sunscreen.  It seems that we will now be required to document sunscreen application every time it is applied.  This seems especially excessive in the summer when we take the school age children to the pool and apply the sunscreen multiple times during the visit.  I understand documenting other over the counter skin products that are not regularly applied multiple times a day every day, but this is going to be burdensome for many programs.

8VAC20-781-580 Topical skin products

In the section below, there will need to be some definition on infant foods.  Once the child is eating solid food (prior to 12 months), some parents send in "left over dinner" food to be heated up.  Is it really expected to heat that up by soaking it in water?  There needs to be a way to heat it up, mix it, and test for temperature.  Heating up leftover foods in water, I cannot see as being health department approved.   

8VAC20-781-630 Special feeding needs

I. Milk, formula or breast milk, and bottles of infant foods shall be warmed under running warm tap water or by placing them in a container of water that is no warmer than 120° F. Bottles and infant foods shall not be heated or warmed in a microwave.

In the section below, this is a huge change.  Sandboxes have only ever been required to be covered when the sandbox cannot drain.  For example, I have a large sandbox that is just on the ground, we do not have issues with animals using it, and it drains properly when it rains.  To cover it, is going to require some type of tarp, that I think would be more of a hazard than just leaving it uncovered as the tarp will collect water that doesn't drain.

8VAC20-781-260 Indoor and outdoor play areas and equipment

J. Sandboxes shall be covered when not in use.

I appreciate you taking the time to review these potential issues and hope that as a previous commenter stated, the state can help to make hiring an easier process.  Right now, it takes at the bare minimum a month from interview to hire.  Fingerprint checks need to continue to be funded by the state or the price significantly reduced similiar to the CRS check.  Potential employees making minimum wage or barely above don't have the funds to pay for them and the employers don't have the funds to get people fingerprinted that aren't going to show up.  There has to be a way to keep the funding for fingerprinting going.