| Action | Amend regulation to require each 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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Tara Ford
Sterling, VA 20164
December 3, 2025
RE: Public Comment on Proposed Mandatory Stock Epinephrine Requirement
My name is Tara Ford, and I am a licensed child care provider in Sterling (Loudoun County), Virginia. I am writing to express my concerns about the proposed requirement that all childcare facilities maintain stock epinephrine auto-injectors (EpiPens) for emergency use.
I have been providing childcare for 22 years and currently care for 11 children, ages 2 to 11. My facility is a small family/home-based childcare facility. I am deeply committed to the safety and well-being of every child in my care.
While I absolutely support keeping children safe, I have serious concerns about this proposed mandate that I believe need to be addressed before implementation.
My serious concerns are as follows:
• Financial burden of purchasing and maintaining EpiPens plus training costs
• Lack of medical training to diagnose anaphylactic shock or determine the need for epinephrine
• Fear of causing serious harm through accidental injection or unnecessary administration
• Concern about dosing errors with children of different ages and sizes
• Unclear liability insurance coverage and risk of lawsuits
Better alternatives exist, such as requiring prescribed EpiPens from parents with known allergies. I support child safety but ask that you work with providers on practical, sustainable solutions. I believe there are better approaches that would protect children while being practical for providers:
• Requiring parents of children with known allergies to provide prescribed EpiPens for their specific child.
• Improving emergency response times in our area.
• Providing training on recognizing allergic reactions and when to call 911.
• Creating a voluntary program with state funding and full liability protection!
I want to emphasize that I take the safety of children very seriously. However, I respectfully ask that you reconsider this mandate and work with providers to develop solutions that are both effective and practical.
Thank you for considering my concerns. I am happy to discuss this further and appreciate the opportunity to provide input on this important issue.
Sincerely,
Tara Ford