I strongly oppose this amended regulation.  

Childcare staff are not medical professionals, and requiring them to make rapid, high-stakes medical decisions about whether a child with no diagnosed allergy needs an epinephrine injection is not fair.  Misinterpreting symptoms or administering medication unnecessarily could create serious safety risks.  Not to mention the liability if a medical mistake is made, both for the center and the staff member forced to make a decision.  We are not allowed to administer common medicines like Tylenol without proper paperwork and parent consent-- I am not comfortable administering epinephrine without the same- or requiring my staff to do so.

This mandate also places a significant financial burden on already struggling centers.  Epinephrine auto-injectors are expensive, must be purchased in multiple weight-based doses, and expire quickly- requiring continual replacement even if never used.  This is an added expense that makes running a center even more difficult.

For these reasons, I respectfully oppose this amendment.