8VAC20-781-490. Hand Washing 

D. The licensee shall ensure that staff wash their hands with liquid soap and running water: 

Before and after: 

a.  Helping a child use the toilet 

    RESPONSE: (This should be moved to the “After” category) 

b.  A diaper change 

RESPONSE: (When gloves are used, this should be moved to the “After” category) Requiring washing hands prior to changing a diaper is a waste of time and energy if the teacher wears new disposable gloves for each diaper change. 

e. Administering medication or over-the-counter skin products. 

RESPONSE: (spraying on sunblock or applying any skin product that does not involve touching should be eliminated from this. If staff are supervising children at a swimming facility and it’s time to re-apply sunscreen, this is overly burdensome for staff to find a sink with liquid soap and running water to wash hands prior to applying) 

E. The licensee shall ensure that staff wash their hands with liquid soap and running water when their hands are visibly dirty and when entering the classroom before working with children. 

RESPONSE: 

We suggest removing “and when entering the classroom before working with children”. Staff are required to wash their hands prior to helping with toileting, diapering, preparing and feeding children, and administering medications as well as when visibly dirty. The staff’s attention should be focused on the children when entering the classroom. 

8VAC20-781-500 Diapering and toileting  

J. The storage system required in subsections G and H of this section shall be cleaned and sanitized daily.  

RESPONSE:  

Requiring teachers clean and sanitize the diaper trash system daily seems unnecessary. While cleaning is generally good, it seems like 8VAC20-781-500 J. which requires daily cleaning and sanitizing of the diaper trash system, is a lot more work for minimal benefit. The diaper trash can has a liner that's removed, and daily cleaning and sanitizing of the cans would take probably 30 minutes a day in a medium sized center when the next day you just put another diaper liner and trash in there again. It is already contained, and the cans are never touched because it’s mandated to be a touch-free system. The only time the inside of the can would be handled would be to put in and take out the bags. Perhaps cleaning the exterior of the trash can or in our case the cabinet that contains the diaper system would be appropriate or perhaps the sanitation of the system without the wiping clean. Of course, it would be cleaned if visibly dirty, but it is generally covered in a bag and not touched.  

8VAC20-781-580. Topical Skin Products 

A. When topical skin products such as lip balm, hand lotion, sunscreen, diaper ointment and lotion, and insect repellent are administered by the center, the following requirements shall be met: 

1. Written parent authorization noting any known adverse reactions shall be obtained at least annually; 

2. The product shall be in the original container and, if provided by the parent, labeled with the child's name; 

3. Manufacturer's instructions for application shall be followed; and 

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. 

RESPONSE: 

A. 4. We suggest removing all of this (4 only) for over the counter products for school age children. We support written documentation of any application errors and action taken.  

8VAC20-781-660 Animals and pets 

C. Monkeys, bats, ferrets, poisonous animals, reptiles, psittacine birds (birds of the parrot family), stray animals, or wild or dangerous animals shall not be in areas accessible to children during the hours children are in care. 

RESPONSE:

Reptiles make excellent, safe class pets. Most of our centers have reptiles (box turtles, bearded dragons, leopard geckos) all kept in aquariums. Children do wash their hands after handling the animals. The new regulation 8VAC20-781-660 C forbids reptiles along with bats and monkeys (both of which are much more dangerous disease vectors). Classroom pets present great opportunities for learning, and compared to mammals, reptiles tend to be less stressed by the classroom environment. I encourage you to remove “reptiles” from the list of animals that are forbidden.