Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Voluntary Registration of Family Day Homes - Requirements for Providers [8 VAC 20 ‑ 850]
Action Amend regulation to require each voluntarily registered family day home provider or other caregiver to be trained in epinephrine administration; notification requirements to parents required
Stage Fast-Track
Comment Period Ended on 12/17/2025
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Previous Comment     Back to List of Comments
11/25/25  11:56 am
Commenter: Susan Gallier, Susan;s Day Care

EipPen
 

I see many potential concerns with the use of epinephrine in childcare settings. Having been in this field for over 30 years, I worry that inexperienced or frightened providers may administer it unnecessarily especially to children. This could create serious complications that would be extremely difficult to address afterward.

The cost of EpiPens is also prohibitive for many providers. Even if they are supplied at no charge initially, they expire regularly and would need to be replaced. That creates an ongoing financial burden. From what I understand, providers would be responsible for maintaining these pens, and that would be an undue hardship for me.

Although I am MAT trained, I am not comfortable keeping an EpiPen in my home or administering it to a child who has not been previously diagnosed by a doctor. Certain medical conditions can mimic allergy symptoms, and giving epinephrine in those situations could make the emergency worse. For these reasons, I believe this approach is risky, reckless, and ultimately irresponsible.

In my opinion, our efforts should focus on increasing allergy education in daycares rather than placing this level of medical responsibility on providers. In the event of an emergency, the safest course of action is to call 911 and allow trained medical professionals to handle the situation.

 
Susan Gallier
CommentID: 238037