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

Background: In Montessori environments, toilet learning begins when a young child is mobile and exhibiting interest in dressing/undressing themself. In a toddler classroom, therefore, all [BCM(1] children are in the process of learning to toilet independently. As part of that learning, changing takes place in the bathroom; toddlers stand during the process and actively participate in the process of changing clothes and “freshening up” when necessary. We commend, therefore, the proposed guidelines’ addition of the following language:

"Diapers or disposable training pants of children who are toilet training may be changed in the bathroom, and not on the diapering surface required in subdivision 3 of subsection D of this section, but the required procedures for handwashing in 8VAC20-781-490 and disposal of diapers or disposable training pants in subsections G and H of this section shall be followed."

Recommended addition: Diapers, disposable training pants, or underwear...

In the past, Virginia’s Montessori programs have struggled with inconsistent interpretation of diapering/toileting regulations, with some inspectors permitting toddlers to change in the bathroom (not on a changing table) and others strictly prohibiting it. For clarity,  we provide this video, produced by Child Care Aware, demonstrating safe and sanitary procedures for standing diapering of toddlers in the bathroom.