30.G  Operational responsibilities 

Eliminate or rewrite all standards relating to undesignated or stock epinephrine. Not only does this requirement conflict with other standards it will be financially burdensome for centers, centers will have increased liability, it is unsafe, and beyond the scope of childcare staff

130.D Orientation training

Include language that permits those who became directors before the department created prelicensure orientation do not have to complete this training.

140 Ongoing training

Delete “The ongoing training shall not include the training required by 8VAC20-781-130 C.”

Allow CPR and First Aid training hours to continue to count toward annual training.

170.C Medication administration training

Eliminate the requirement that pertains to stock epinephrine.  

250.J  Indoor and outdoor play areas and equipment

Retain former language. Some sandboxes are too large to cover.

260.F  Supervision of children

Define physical barrier. Would this include bookcases, etc.?

270.A.5 Staff-to-children ratio and group size requirements

A group size of 100 children ages 5-12 is too large for 5 staff to supervise, especially on field trips to parks, etc. where children are spread out.

270.B.5 Staff-to-children ratio and group size requirements

Twenty children are too many for one staff person to safely supervise, especially during homework time when many children require one-on-one assistance. During the summer the ages could range from four years 8 months to 12 years 11 months, making supervision more difficult. 

320.B.2 Daily care and activities for infants

Please make this more restrictive. Do not expose children to hazardous air quality conditions.

340. A. Daily care and activities for toddlers, twos, and preschoolers

Please make this more restrictive. Do not expose children to hazardous conditions of any type, even air quality. 

400.J.7. Parent communication and notification

Not all accidents, such as tripping while running outside, have a clearly defined method to prevent reoccurrence. Add “if applicable” following future action to prevent reoccurrence.

420.D. Play furnishings, equipment, materials, and toys

Delete the requirement for dress up clothes, stuffed animals, cloth dolls to be washed weekly. Not only will this be financially burdensome for the center, but most of the items will not survive a weekly washing. Not every center has in-house laundry facilities and majority that do are using them to the max.

430. H. Cribs, cots, rest mats, and beds 

Clarify why cots need to be covered with a nonabsorbent material or delete it.

450.H.3. Swimming and wading

Remove requirement for lifeguard competency and qualifications at a public pool or lake. Outside facilities do not make this information available to centers. How will licensing inspectors enforce this? 

480.D.1.a. Hand washing

Delete the need for staff to wash hands before helping a child use the toilet. Many times, they are only called on to help with outer clothing that a child cannot fasten, etc. 

510. Requirements for medication administration

Requiring undesignated or stock epinephrine takes away freedom of center to decide if the center will administer that medication. It also conflicts with:

• Requiring obtaining written parental authorization for medication before a medication is accepted, maintained, or stored at the center 
• Medication shall be labeled with the child's name.
• Medication shall be given to a child only with written authorization from the parent that has not expired.

520.3 Prescription medication

Requiring undesignated or stock epinephrine conflicts with this standard as no specific child is named.

570.D. Topical skin products

Delete hand soap from this list of products children may not self-administer. This will interrupt a teacher’s valuable teaching time as she will be required to stop any activity and physically go over to the sink to put soap on the hands of a child. Has any child in a childcare setting been harmed by using hand soap unsupervised or that was self-administered?  

610.J. Nutrition and food services

Delete sanitizing tables after each use. Tables are required to be sanitized before the next use.

610.L. Nutrition and food services

Please delete requiring children to remain seated while drinking. This standard will eliminate use of all water fountains. When hiking and during outdoor play children may need to sit on the ground while drinking from a water bottle.