We strongly support protecting children from severe allergic reactions. However, we respectfully but firmly oppose this mandate in its current form and urge its removal from the fast-track process.
Mandating non-medical childcare staff to assess symptoms and administer a powerful prescription drug to children without a diagnosed allergy significantly increases liability exposure. In an industry already struggling with skyrocketing liability insurance premiums, this new risk could drive premiums even higher – further threatening the financial viability of childcare programs throughout the state.
The regulation imposes unfunded costs ($290–$850 per device + replacements every 12–18 months).
Fast-tracking bypasses the thorough stakeholder engagement, cost-mitigation exploration, and standard rulemaking process that such a resource-intensive mandate requires.
We urge VDOE to withdraw the proposal from fast-track consideration, pursue standard rulemaking, and work collaboratively with stakeholders to develop alternatives that enhance safety without jeopardizing the stability of Virginia’s childcare system.
