I am writing in opposition to the proposed amendment to the Standards for Licensed Child Day Centers (8VAC20-780) requiring centers to possess and administer stock epinephrine.

I am an Administrator at a childcare center in Bridgewater, Virginia, and I have significant concerns regarding the safety, training, and liability risks this amendment places on centers and their staff. Our educators and caregivers are not medically trained professionals, nor do they have the clinical expertise to assess and determine when a child—who does not have a known allergy or an epinephrine prescription—requires emergency administration of an epipen. This level of medical judgment goes far beyond the scope of training and responsibility appropriate for childcare staff.

The liability associated with administering epinephrine to a child without a documented need is astronomical. Even with training on how to administer the medication, staff cannot be expected to diagnose anaphylaxis, differentiate it from other medical conditions with similar symptoms, or make a high-stakes medical decision with potentially life-altering consequences. This creates significant risk for staff, centers, and, most importantly, the children in our care.

While I understand that Chapter 122 and Chapter 123 of the 2023 Acts of Assembly, as well as § 22.1-289.059 of the Code of Virginia, prompt these amendments, the requirement that any employee—rather than a licensed medical professional—administer epinephrine is deeply concerning. Childcare centers are not staffed like schools with full-time nurses. Many centers, including ours, do not have a school nurse on site. Requiring an employee to act in this medical capacity is unrealistic and unsafe.

Additionally, the mandate to maintain appropriate weight-based dosages of stock epinephrine accessible at all times introduces further logistical and financial burdens. Childcare centers already operate under strict regulatory requirements and tight budgets. Adding high-cost medical supplies, secure storage, documentation procedures, and ongoing staff training—without staffing medical personnel—creates significant strain.

In closing, I urge the Board to reconsider this amendment or revise it to ensure that only medically licensed personnel are permitted to administer stock epinephrine, or that an alternative approach be implemented that does not place childcare staff in positions requiring medical judgment beyond their training.

Thank you for the opportunity to provide input on this important matter.