The requirement that "4. A record shall be kept that includes the child’s name, the name of the product, date and time of use, any adverse reactions, and any application errors and action taken."   for ALL over the counter topical applications is incredibly burdensome - and will result in those applications not being used.  There is no practical way to record for every child in the group every time sunscreen is applied during the summer months - it is challenging enough to get it applied! - and during the winter, every time a child needs lotion or lip balm. PLEASE support the important health practice of using sunscreen by not making it so impossible that it can't realistically be done in center-based care.