8VAC20-781-40 Required policies and procedures

To Whom It May Concern,

Thank you for the opportunity to comment on 8VAC20-781-40 Required Policies and Procedures. I am Alicia Rhyne, a close friend to Rebecca and Peter Toohey. Bodie should have been turning one last month, but due to unsafe sleep practices at his childcare he passed away on March 4th, 2023. Explaining to my children why their little buddy is no longer here on earth has been the most difficult thing to explain to a 4 & 6 year old and to watch two of my closest friends who I love go through such heartbreak over something that could have been prevented was even more painful. I pray for my friends daily and I pray that no other family has to endure what they have been through. We can change that by  educating other and  becoming advocates to better laws and policies. 

I would like to first thank you for considering a review of the current standards around safe sleep practices as it is a mission we have been working towards to enhance the required standards around this issue to prevent babies in the future from needlessly dying in Virginia Child Care:

1. 8VAC20-781-330 Daily Care and activities for infants. A-H  are wonderful safe sleep standards that will protect infants from dying. 

2. 8VAC20-781-440 J “Cribs should be used for children under 12 months” (I would recommend making this language clearer by mandating cribs be used for infants under 12 months, not doing so increases the risk of infants being put into containers to sleep that have warning labels on them stating the risks. We want to make sure all standards promote AAP’s recommendations).

3. Please reconsider- 8VAC20-781-40 Required Policies and Procedures

   1. There needs to be a direct safe sleep policy that aligns with AAP in the standards to create a universal high-quality care model

   2. Please change to what Religious Exempt Centers are required to follow. It currently reads that “ The licensee shall develop and implement the following written policies and procedures” ADD that comply with the MOST UP TO DATE Safe Sleep guidelines recommended by the AAP.

4. All standards should align with the American Academy of Pediatrics as clearly as possible so all providers develop and maintain safe sleep policies that address all of these updated provisions. 

In summary, this review is a step in the right direction of protecting our community's children in child care settings. However, more work needs to be done and our standards need to be clear and align with AAP to meet the most up to date research as it comes out. We want our childcare providers to meet the needs of children as they evolve in regards to safe sleep. Having language that can be flexed due to being vague in its nature leaves too much room for providers to make risky decisions that have ultimately led to innocent babies losing their lives. 

Sincerely,

Alicia Rhyne