On the VDOE webinars we always hear how the regulations are "data-driven." Where is the data that says that stock epipens will save lives? It should be published for providers and the public to see.

How many unknown, undiagnosed sudden anaphylactic reactions resulted in the death of a child in childcare last year in Virginia? Was it zero?

Children with anaphylactic allergies already have epipens, along with carefully designed medical plans for when to administer. 

You could have addressed the state law by amending the regulations requiring MAT administration and administration of emergency/rescue meds to allow childcare providers the benefits enjoyed by other Virginia citizens under the Good Samaritan laws. Instead, you swung the regulatory pendulum in the complete opposite direction, creating a huge unfunded expense. Every single provider in Virginia will now pay hundreds (or possibly $1,000+ if you need multiple weight/dose) every year.

In addition, you have created a huge legal liability for providers.

You need to postpone the implementation of this regulation until the legislature can fix the law that they never should have passed.