I am a parent of two children who have attended early childhood care at a licensed facility in the state of Virginia. Topical ointments are not medications and should not be subjected to the same level of documentation that medications are. 

The new language of 8VAC20-781-580 A 4 (“A record shall be kept that includes the child’s name, the name of the product, date and time of use, any adverse reactions, and any application errors and action taken”) is too burdensome. Please allow providers to continue to use parent authorized topical ointments without detailed documentation of each application.

Creating additional documentation burden does not increase safety and runs the risk of licensed centers limiting outdoor time to avoid having to re-apply things like sundcreen. Children need as much time outside as possible. This new language jeapordizes children’s access to non-medical ointments and outside time.