Thank you for your careful review of all comments during this public commenting period before you begin your next round of revisions to the Standards for Licensed Child Day Centers in Virginia. I am a member of the Our Neighborhood Child Development Center community, with two children attending there, ages 2 and 5. I would like to offer a general seconding of all the teachers’ comments that have been submitted, and in particular those of Jennifer Slack, the program director, some of whose comments I have lifted and reiterated as my own below. These educators have a keen understanding of how these regulations will affect their day-to-day work and their ability to provide high-quality care. I am also a former Certified CLASS^® Observer at the Infant, Toddler, Pre-K, and Upper Elementary age levels, with a strong understanding of what high-quality child-care looks like and what children need to thrive.

In particular, I would like to add my voice to the following comments:

1. New detailed documentation of topical ointment use would create a huge administrative burden and possibly lead to providers not allowing topical ointments for children whenever possible. As a parent at ONCDC, I am grateful for the school’s provision of sunscreen for the children. They research effective, environmentally friendly products and buy them in bulk in support of our sustainability values. Not to mention that it is one less thing for me as a parent to juggle and label every day. I fear that if required to report all applications of topical ointment, the school would no longer want to provide this service. The current standards do not require this reporting, I do not require it as a parent, and I would advocate we not add this significant administrative burden into our state’s regulations. If more documentation is necessary, perhaps, for infants and toddlers, this documentation could be part of their daily documentation. As a parent I find having all information about my child’s day in one place helpful.
2. Proposed language would prevent children two years old and younger from being on a playground with three-year-olds and above, likely resulting in reduced outdoor time and programs that don’t serve infants being unwilling to serve two-year-olds. My two-year-old and five-year-old benefit greatly from being able to play with each other—and each other’s peers—on the playground at school. I have seen how playing with older children has increased my two-year-old’s confidence and competence. I have seen how playing with younger children has increased my five-year-old’s caring and carefulness. Further, both of my children would have less access to outside time if intermingling on the playground was not permitted. Perhaps the best way to regulate any safety concerns around mixed ages on the playground would be to require that playground safety plans (8VAC20-781-40 A 4) include policies for how, if, and when different ages will engage together on the playground, how younger children will be kept safe, and how ratios appropriate to the youngest child will be maintained for the group. At the very least, twos should be removed from the regulation as written to minimize the impact of this change.
3. New language restricting visual media (screens) does not go nearly far enough. Toddlers, which the standards define as children more than 16 months and less than two, should not be viewing any visual media in the child-care setting. As a parent, I would not tolerate screens in an infant or toddler setting, and permitting this within our state standards will reduce the already limited options that parents who are seeking high-quality care for their children have. Additionally, I think there needs to be stronger language to protect two-year-olds and preschoolers because two hours a day at school is far too much time on screens. My recommendation would be to limit children two and older to no more than 30 minutes per day. Children should not be babysat by screens in our early childhood programs. 
4. New language may unintentionally restrict loose part and recycled material use. “Disposable products shall be used once and discarded” creates a lack of clarity about the use of recycled materials for play. Recycled materials have an important place in a high-quality learning environment. The new CLASS Environment^™ has an item that measures whether “recycled materials that children encounter in day-to-day life are available.” This assessment item has a detailed rationale for inclusion, which includes “recycled materials represent and abundant, sustainable source of objects that lend themselves to open-ended play” and lists examples such as paper towel rolls and empty jars. It was probably not the intention of this standard to exclude the use of these items for play, so I would request adding a clarification such as, “Clean and safe recycled materials may be used for play.”
5. We are missing an opportunity to advocate for water and not other beverages for children. Children should only be drinking water throughout the day. 8VAC20-781-620 D allows other beverages and should be changed to remove that option. This is consistent with USDA CACFP guidelines which require water throughout the day and other beverages only with meals. As a parent, I would not tolerate a child-care setting that offered juice or other beverages, and permitting this within our state standards will reduce the already limited options that parents who are seeking high-quality care for their children have.
6. Throughout the standards, there is inconsistency in the use of terms around behavior. “Discipline” is used in 8VAC20-781-390. “Behavior guidance” is used in 8VAC20-781-380, 8VAC20-781-120, and 8VAC20-781-40. “Behavioral problems” is used in 8VAC20-781-410. “Classroom management” is used in 8VAC20-781-290 and 8VAC20-781-140. In its recent major revision to the Classroom Assessment Scoring System^®, Teachstone revised the dimension of Behavior Management for the Pre-K age level to be Behavior Guidance, consistent with the language used in the Toddler CLASS tool. Not only is “behavior guidance” more descriptive of effective practices, it is also an important equity measure. Research shows that harsh discipline is disproportionately leveraged against racially minoritized children, even to a large extent in preschool and child-care settings. Behavior is communication, and children under the age of five, who are still developing many key executive function skills should not be treated as problematic or disciplined for exhibiting normal behaviors such as biting, hitting, throwing, or screaming, regardless of how challenging adults may find these behaviors. I would recommend using the language of “behavioral guidance” wherever possible to align with the most up-to-date thinking in the field.