Our center uses topical ointments in our program. 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. We regularly apply parent-provided sunscreen to 15 or 20 children at a time. Stopping to document this each day after already being given permission from the family will prevent valuable supervision and playground time. Please allow providers to continue to use parent authorized topical ointments without this level of detailed documentation on every single application.