We believe children need access to softness in early childhood environments. Rigid regulations will reduce children’s access to cloth and soft items. 

Proposed Regulation

8VAC20-781-420 Play furnishings, equipment, materials, and toys

D. The following cloth items provided by the center shall be washable: stuffed animals, cloth dolls, and dress-up clothes; floor pillows shall be washable or have removable covers that are machine washable. When used by children, the center shall wash stuffed animals, cloth dolls, dress-up clothes, and pillows or removable covers, at least once a week or when soiled.

Is the proposed regulation regulating something that is happening or likely to happen? 

Yes, it is important that early childhood environments have soft items and it is likely they would get dirty regularly, in an early childhood environment. 

Is this a health or safety concern?

If soft items were not able to be cleaned or were never cleaned it could cause the spread of germs.

What is the appropriate regulation to address the safety concern?

There are already regulations that require areas and equipment to be kept clean (8VAC20-781-210 A). There may be a need for clarification that that includes materials or cloth items but largely we believe that educators understand their role to maintain a clean environment. The addition of 8VAC20-781-420 D is unnecessary and could be safely stricken from the draft regulations. It is already clear that they should be cleaned as needed in 8VAC20-781-210 A.

We reviewed violation data and confirmed that a violation of 8VAC20-800-480-E was issued on Aug. 13, 2024 for uncleaned stuffed animals and a violation of 8VAC20-780-270-A was issued on Aug. 14, 2024 for unclean boppy pillows. 

What are the possible unintended consequences of the current proposed regulation?

We invite you to consider how you care for soft items in your home and though a child care center would have much heavier usage, weekly washing is untenable. Our school has stuffed animals and nugget floor cushions which have removable covers but it would take a significant amount of washing machine time, teacher time, and teacher effort to remove the covers on all items to wash them. We also have couches in many of our spaces which are not machine washable and do not always have removable covers. 

In our program, we wash things like the covers for our Nugget couch cushions and futon covers monthly, which seems a lot more practical and much less likely to have unintended consequences. Imagine a child’s stuffed animal, how many washes do you think it could sustain. Weekly washing also ages items very quickly which would mean that programs need to replace items more frequently. Weekly washing will decrease the quality of the materials available to children. Our washing machine is always running so we would likely need many additional items to be able to maintain soft items in the classrooms. 

Ultimately the most likely consequence of this regulation is that it would decrease young children’s access to soft items in their environment. Already tired teachers will reduce the stuffed animals, dress up clothes, and floor pillows that make classrooms cozy because weekly washing is not sustainable. We know that home like environments reduce stress for children while they are away from their homes. Sterile early childhood environments are not high quality spaces for children. 

Strike 8VAC20-781-420 D and we look for ways to increase children's access to soft items not reduce access