We strongly oppose the legislation that would force us to stock and administer epinephrine for the following reasons: 

1. Our staff are not medical professionals and might easily 'misjudge' a presumed anaphylactic reaction. The training you offer 'free of charge' only speaks about administration of epinephrine, not about recognizing the symptoms and how to differentiate from other symptoms or more common issues, e.g. hives, rashes, astma.
2. Staff might not feel comfortable providing a serious, complicated medical procedure, as they have chosen the education field, not a medical career. Not being comfortable might lead to mistakes and misjudgment. 
3. As someone needs to have access to the epipen at all times, we would need to have 5-6 'trained' staff, as they work at different times of the day. This is an administrative burden and takes time away from their regular tasks, if they need to be trained.
4. The cost burden is significant and recurring, with epipens having an expiration date of 2 years. With having to 'buy' a new supply of epipens every 2 years for multiple age/weight groups will put a financial burden on providers. If they are not used - which we hope- it will be a total waste of a medical provision that might have been used for someone who actually needed it.
5. The liability insurance will become more expensive, and we will probably need to add a malpractice insurance or a professional liability Insurance on top of the general liability insurance.
6. We assume we would need parental permission of our parents that they would approve of epinephrine administration for their child in the event of a 'presumed' anaphylactic shock. We are sure they will have questions on how we will diagnose and who will administer. This will create an administrative burden and hard to keep track of who opted in/out. 
7. We are missing a whole lot of clarification from the department:
   1. Is there a form for parents to opt in/out of administration of epinephrine.
   2. how would we get the epipens - has the VDOE secured a contract with pharmacies for a constant supply of epipens to be bought by all VA schools? Or are we supposed to call individual pharmacies to see if they are willing to 'sell' us some epipens. And who will determine the correct dose - do we need to weigh all children and keep a log of their weight??
   3. How will the data tracking take place - assuming that the VDOE would want to know - on how often used for undefined situations, how many correctly judged, how many misjudged, consequences and side effects of wrongly administered epipens..... etc.
8. This 'new' law is actually not new, as the Code was already finalized in 2022. So, the past 3 years, this was not an issue, and all of a sudden it is on the fast track to be pushed through without any additional information on procedures or logic.