I am writing to oppose the addition of 8VAC20-781-420 D, which mandates the weekly washing of all soft cloth items, as it is both legally redundant and unnecessary for safety. The Department already possesses sufficient regulatory authority to ensure clean environments under 8VAC20-781-210 A, a standard that is currently effective. A review of violation data confirms that inspectors are already successfully identifying and citing issues with cleanliness—such as the violations issued in August 2024 for unclean soft items—demonstrating that the current "clean as needed" standard works. Adding a rigid weekly prescription creates administrative bloat without addressing a genuine safety gap, as educators are already held accountable for maintaining sanitary conditions under existing regulations.

Furthermore, the operational burden of this proposed regulation will have severe unintended consequences for the quality of care. Mandating the weekly washing of every stuffed animal, dress-up outfit, and floor cushion is logistically untenable for high-quality centers that prioritize "soft," home-like spaces over institutional sterility. To remain compliant with such a rigid schedule, providers will be forced to simply remove these comfort items to avoid the impossible labor of constant laundering and the rapid deterioration of materials. We urge the Department to strike 8VAC20-781-420 D and rely on the existing standards to ensure children do not lose access to the comforting textures that are vital for reducing stress and supporting emotional well-being.

To summarize, the proposed regulation is redundant and operationally burdensome. Existing standards already allow inspectors to cite unclean items (proven by recent violation data). The strict "weekly washing" mandate will unintentionally force providers to remove comforting soft items to stay compliant, resulting in sterile, lower-quality environments for children.