I respectfully submit this comment in opposition to the fast-tracking of the proposed regulation requiring all child day centers to maintain policies and procedures for the possession and administration of epinephrine.

This amendment creates significant legal and safety concerns for childcare providers. Under both state and federal law, prescription medication cannot be administered to anyone other than the individual for whom it is prescribed. This proposal essentially places childcare staff in a position where they could be expected to identify when epinephrine is needed and administer a specific dose—tasks that fall far outside our training, authority, and legal protections. The contradiction is clear: we are not permitted to give a child Benadryl or even apply diaper cream without written parental consent, yet this regulation would require us to handle a medication that carries far more serious risks and effects that can last for days.

There is also a substantial financial impact that has not been fully considered. For many centers, including my own, the annual cost of maintaining epinephrine devices would fall between $2,000 and $2,400, and these devices expire every year. Childcare programs are already facing staffing challenges, rising operating costs, and limited financial resources. Adding another unfunded mandate of this size is simply not feasible.

For these reasons—legal conflict, safety concerns, and significant financial burden—I strongly urge the Board not to fast-track this amendment. A requirement of this magnitude deserves a full review process that allows for careful analysis and meaningful stakeholder input.