I am submitting this comment as a childcare staff member with professional responsibility for the daily care, supervision, and well-being of young children. Based on my experience and understanding of current childcare regulations, I strongly oppose the fast-tracking of the proposed amendment requiring all child day centers to maintain and administer epinephrine on site.

This proposal introduces significant legal, procedural, and safety implications for childcare personnel. Current state and federal regulations clearly prohibit the administration of prescription medications to individuals for whom they are not prescribed. Childcare staff are not licensed medical professionals, yet this amendment would effectively require us to evaluate symptoms, make medical judgments, and administer a prescription drug with potent and lasting effects. Under existing standards, staff cannot administer over-the-counter medications such as Benadryl, nor are we permitted to apply simple topical products like diaper cream without written parental consent. Epinephrine, which can remain active in a child’s system for an extended period and carries well-documented risks, exceeds the scope of what non-medical providers are trained or authorized to administer.

In addition to these concerns, the financial strain this requirement would place on childcare centers is substantial. Epinephrine devices expire annually, and for many programs—particularly those serving diverse or low-income communities—the annual cost of $2,000 to $2,400 represents a significant operational burden. Such unfunded mandates place considerable stress on already limited budgets and may ultimately reduce access to high-quality childcare for families across the Commonwealth.

For these reasons, including the legal conflicts, medical risks, and financial implications, I strongly oppose fast-tracking this amended regulation. A requirement of this magnitude warrants a full, deliberate regulatory review process that includes comprehensive stakeholder input, evidence-based evaluation, and thoughtful consideration of its impact on children, families, and the childcare workforce.