Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Family Day Homes [8 VAC 20 ‑ 800]
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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12/3/25  2:55 pm
Commenter: Tara Ford

Epi Pen Mandates - Uneccessary
 

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

 

CommentID: 238372