I am an Infant and Toddler Specialist who has been advocating for change in the standards to ensure infants, families and caregivers are safe regarding safe sleep and infant health and safety in general.  I want to sincerely THANK YOU for the following proposed standards.  I have met too many parents who have lost their children from unsafe sleep and this is a big step in preventing future babies from needlessly dying in Virginia Child Cares.   

8VAC20-781-330  Daily Care and activities for infants   A - H are all fantastic standards that will help protect babies. 8VAC20-781-340 Resting and Sleeping infants   A-G align with Safe Sleep Guidance from AAP  8VAC20-781-440  J CRIBS SHOULD BE USED FOR CHILDREN UNDER  12 MONTHS and O No soft objects in the crib   These few proposed changes have been proven to lessen the likelihood of infant deaths from unsafe sleep practices.    

PLEASE RECONSIDER- 8VAC20-781-40 REQUIRED POLICIES and PROCEDURES (too vague)  please change to what Religious Exempt Centers are required to follow :          "The licensee shall develop and implement the following written policies and procedures.  3. THAT COMPLY WITH THE MOST UP TO DATE SAFE SLEEP GUIDELINES RECOMMENDED BY THE AMERICAN ACADEMY OF PEDIATRICS"

Thank you for your consideration.