I am strongly opposed to centers being required to stock and administer epi pens.  I am opposed to this for a multitude of reasons including the following:

1. I am strongly against the idea of putting the responsibility on my teachers to administer any medications to a child that is not prescribed to them.  Despite how well they are trained, my teachers are not medical professionals and I do not think that they should be responsible for administering stock medications to a child.  I think there are too many liabilities associated with this process and I think there are not enough established policies in regards to those liabilities.
2. I have concerns relating to what the process of maintaining an epi pen is; where does it need to be stored, how do we tell if the epi pen has gone bad, what happens when an epi pen does go bad and we can't get a new one quickly to replace the bad one, what are the liabilities if we administer an epi pen that has gone bad.
3. The cost of these epi pens is astronomical and to be required to carry these epi pens without any thought to current drug costs or future drug costs is devastating to small business owners.
4. Another concern is with the families of these children who attend my center.  Am I, as the center's owner, going to be required to get written permission from every family stating that they agree to have my teachers administer a stock epi pen?  In addition, what happens if they do not want my teachers to administer a stock epi pen - what would the liabilities be following that situation?

Because of these reasons, I feel like fast tracking these regulations would be a disservice to families and children who attend daycare centers as well as the owners, directors and teachers.  These regulations need and require more thought behind developing them and more thought and cooperation in regards to identifying the liabilities behind them.  In addition, given more time, creating a grant or finding funding to help pay for stock epi pens would be helpful.