In our fifth decade of providing child care and education throughout the Commonwealth, we acknowledge and appreciate variety in program spaces, to include outdoor play areas.  That being said, we recommend that the Department adopt additional standards in the interest of providing the safest outdoor play areas for children at all facilities.  The first should require some type of fence or natural barrier around the play area.  The purpose of the barrier would be to assist staff members in supervising children, keep unwanted persons, pests, or animals out of the area, and prevent access to other dangers, such as water hazards or traffic.  Second, fencing material should not present a hazard to children and fence gates should be kept closed except when persons are entering or exiting.  Finally, the facility should be equipped with an outdoor play area that is directly adjacent to the indoor facility or that can be reached by a route that is free of hazards and, if walking, no farther than one-fourth mile from the facility.  The current exception to standard 22VAC40-185-330 should remain.   Other states, such as Florida and Georgia, have already recognized the importance by adopting similar standards.  Our recommendation is also supported by industry experts, including the U.S. Department of Health & Human Services [see their 2015 publication “Caring for Our Children Basics Health and Safety Foundations for Early Care and Education”] and The National Association for the Education of Young Children.