Please clarify why it is necessary for centers not licensed for infants or toddlers, and that will never have them on site, to be required to have written procedures for coping with crying babies, safe sleep practices, or sudden infant death syndrome awareness. Also, clarify how the procedures should be written since they will never be put into practice.

22VAC40-185-40 Operational responsibilities

K. The center shall develop written procedures for prevention of shaken baby syndrome or abusive head trauma, including coping with crying babies, safe sleeping practices, and sudden infant death syndrome awareness.