I respectfully submit this comment in opposition to the proposed fast-track regulation that would require all licensed centers to maintain stock epinephrine injectors on-site. While I recognize the importance of responding quickly to severe allergic reactions, this regulation as proposed raises significant concerns regarding feasibility, cost, liability, and the rushed nature of its adoption.

First, the fast-track process circumvents meaningful stakeholder engagement. Implementing a medical requirement with both financial and legal implications for childcare providers, schools, or community centers warrants a full public comment period and impact assessment. Rushing such a measure risks unintended consequences for compliance and safety.

Second, the financial burden of obtaining, storing, and replacing expired auto-injectors falls heavily on smaller or non-profit centers already operating with limited budgets. The cost of multiple devices, annual replacement due to expiration, and potential training requirements would add new unfunded mandates without clear funding support.

Third, liability and training concerns remain unaddressed. Administering epinephrine is a medical act that should only be performed by trained individuals under clearly defined protocols. The regulation must clarify who bears responsibility in cases of improper administration or adverse reactions.

Finally, while I strongly support measures that keep children and participants safe, policy decisions of this magnitude should be made through a deliberate and transparent process, grounded in consultation with healthcare professionals, educators, and affected operators—not through a fast-tracked rule that limits discussion.

For these reasons, I urge the agency to withdraw or slow the current fast-track proposal and instead pursue a more inclusive rulemaking process that ensures safety, practicality, and fairness.

Respectfully Mercedez Hammock.