Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 780]
Action Amend regulation to require each child day center to implement policies for the possession and administration of epinephrine
Stage Fast-Track
Comment Period Ended on 12/17/2025
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12/5/25  5:53 pm
Commenter: Jaime Thompson

Opposed to the proposed changes regarding undesignated epinephrine
 

Thank you for requesting feedback on the proposed changes regarding undesignated epinephrine in the new state law (§ 22.1-289.059 of the Code of Virginia). As the director of an early childhood education program, I do not support these changes.

 
I believe this would place undue financial burden and place unnecessary requirements of staff on early childhood centers, as well as put the safety of our students at risk.
 
Currently, if a child has a medical need, the family must provide any necessary medicine or medical equipment with a physician's detailed instructions for proper administration of such items. Only children with a known/determined need should ever receive this medicine according to MAT training protocols.
 
Having an undesignated epinephrine on hand without a set dosage and without a specific child in mind would be dangerous to our students' safety. Children's weights are unknown UNLESS they have an identified medical need and the dosage has been appropriately determined for their specific weight and identified on their medical administration forms (required by licensing to administer anything) by a medical professional.
 
It goes against all current safety and medical protocols to have such an extreme medication on hand without it being assigned to any specific child. I wouldn't put bug spray or sunscreen on our students without the proper form indicating the need for it and which also guarantees the safety of it for that child. Just applying common sense, any child might have an adverse reaction to the epinephrine - and we would not have any way to know if they would or would not, even with state provided training. The idea of giving a child something so strong as epinephrine without that predetermined medical knowledge/physician's consent of its need and safety for that child would be irresponsible and dangerous in my opinion.
 
If something were to go wrong, would the VDOE take responsibility for having mandated the possession and administration for our programs? I would not encourage my staff to act to in a way that could harm a child through the administration of a medicine not prescribed to them, and so the medicine would simply be sitting there expiring and not in use, while costing our program money we could spend on other needs.
 
I strongly discourage enacting these changes, and thank you for considering the harms this policy could cause.
 
CommentID: 238484