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

Yes! Children are often watching screens while in child care.

Is this a health or safety concern?

Yes, AAP recommends no passive screen use for children under two and that older children’s screen use is limited.

Current licensing regulations do not have any requirements for providers’ use of visual media. Children in child care can watch TV or play video games at any age for any amount of time!

What is the appropriate expectations to address the safety concern?

Good news! The new regulations limit children’s use of screens. The draft standards state:

8VAC20-781-310 Daily activities

C. If the center uses media such as television, videos, video games, software, and computers, the following shall apply:

1. For infants, the use of visual media is prohibited.

2. For toddlers, media use up to two hours per day is permitted if the center operates more than six hours per day.

3. For children two and older, not more than a total of two hours per day, when content is not based on curriculum or educational content.

4. All media provided by the center shall be limited to age-appropriate programs and meet all the requirements in subsection A of this section.

D. Requirements in subdivision 3 of subsection C of this section do not apply to school-age children who attend educational programming that incorporates technology into curriculum learning activities.

Bad news! This still allows children starting at 16 months of age to watch television for 2 hours each day without any requirement to notify parents. For children over two if the content is considered educational, which includes shows like cocomelon, there is no limit on the time that screens can be on for children.

Well regulated visual media use in ECE might look like this:

We can do better! We propose that we put control of media in the hands of parents exactly like the standards require for field trips. Our draft language!

If the center uses media such as television, videos, video games, software, and computers, the following shall apply

1. For infants, the use of visual media is prohibited.

2. Written parental permission for media use shall be secured before the scheduled activity.

3. If a blanket permission is used instead of a separate written permission it must detail the times and types of media that will be permitted.

4. All media shall be limited to age-appropriate programs.

5. Parental permission is not required for school-age children who attend programming that incorporates technology into curriculum learning activities if disclosed in their parental materials.

If this feels too burdensome, we think a basic reporting system where there was a schedule of visual media that is posted to parents the way that a lunch menu is posted and updated would at least be progress towards informing parents.