I respectfully submit this comment in strong opposition to the proposed amendments to the Standards for Licensed Child Day Centers (8VAC20-780) requiring centers to possess and administer weight-based stock epinephrine and requiring early childhood staff to identify and treat anaphylaxis during an emergency.

While the intent behind the regulation is understandable, these requirements are unrealistic, unsafe, and financially burdensome for child day centers.

First, the proposed amendments require that “any nurse at the center, employee at the center, or employee of a local health department” be trained to identify a child “believed to be having an anaphylactic reaction” and administer a weight-based dose of epinephrine. This expectation is far beyond the scope of practice for early childhood educators, the vast majority of whom are not medical professionals. Determining whether a child is experiencing anaphylaxis—especially when symptoms can resemble choking, asthma, vomiting, or panic—requires specialized clinical training. Calculating and administering a weight-specific dose in the midst of a medical emergency adds even greater risk of error.

Second, the proposal imposes substantial financial and operational burdens on child care centers. Maintaining stock epinephrine in multiple weight-based doses, replacing expired medication, securing and documenting storage, and providing specialized medical training for staff represent significant unfunded costs. Additionally, these requirements will lead to increased liability insurance premiums at a time when centers already struggle with staffing shortages and rising operational expenses.

Third, the proposed changes may actually decrease safety. Epinephrine auto-injectors exist precisely to eliminate the need for lay caregivers to calculate doses or make medical judgments under stress. Requiring early childhood staff to manage weight-based dosing contradicts established best practices for emergency allergy response and introduces avoidable opportunities for error.

Child day centers are designed to provide education, care, and supervision—not to function as clinical medical settings staffed by individuals making life-and-death medical decisions. These amendments exceed what is reasonable or feasible for early childhood programs and place both children and staff at greater risk.

For these reasons, I urge the Department of Education and the Board of Education to reconsider or revise the proposed amendments and engage stakeholders in developing a more practical, medically sound, and developmentally appropriate approach.