Comment submitted on behalf of Va's 150+ Montessori programs, and signed-on by 30+ program leaders:

Background: Montessori teachers seek to foster children’s self-sufficiency, independence, and self-development in all aspects of daily life. Young children empowered to independently address their readiness to sleep or wake develop  positive associations with rest and sleeping spaces, and by association, with the caregivers who supervise them during this time. Simple floor beds, like the one pictured below, are safely used in Montessori centers and homes around the nation and world, and allow programs to more holistically fulfill the licensing requirement of 8VAC20-781-320-E, “Children shall be allowed to sleep or rest as individually needed.” They also allow the infant an unobstructed line of sight to observe the world around them. Several states and localities already allow Montessori programs to use floor mattresses. We are asking for state recognition of this widespread, long-standing, and safe practice. For these reasons, we propose the following amendment to the standards, while recognizing that all safety protocols pertaining to cribs (such as those governing placement, spacing, snug bedding, safe sleep practices, etc.) continue to apply to the use of floor beds.

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Existing Language: Cribs shall be used for children under 12 months of age.

Recommended Revision: Cribs or floor beds (standard crib mattresses not to exceed 6” in height), shall be used for children under 12 months of age.