While we all prioritize child safety, these rules duplicate existing protections without addressing core gaps. Here's why they fall short:

1. Existing Rules Already Safeguard Kids with Known Allergies: Current licensing requires individualized health plans, prescribed meds on-site, and staff training per physician orders. Stock epinephrine adds redundancy, not real protection for undiagnosed cases (better handled by 911 calls, as mandated).

2. Liability Risks for Non-Medical Staff: Epinephrine demands clinical judgment—misuse by untrained educators could lead to lawsuits. Free VDOE training helps, but it doesn't make child care providers doctors. Even with the protection afforded by other sections of the Virginia law, we still risk legal action.

3. Unfunded Costs Threaten Program Viability: High device prices, short shelf lives, and storage requirements strain budgets. Without subsidies, this diverts funds from wages, facilities, and access for low-income families. With insurance in the industry already difficult to obtain, this measure also poses the risk of higher insurance rates.

4. Shifts Medical Duties to Educators: Child care isn't healthcare. This blurs roles, overwhelming staff and distracting from play-based learning.

5. One-Size-Fits-All Ignores Early Childhood Realities: Unlike K-12 schools with nurses, centers lack medical oversight. Rules for locked storage and constant access don't fit small operations. Questions remain, like are we required to send a second set of epi-pens on field trips?

6. Better Alternatives Exist: Strengthen family-provider-pediatrician partnerships for known risks. For unknowns, rely on EMS—not universal stockpiles.