Dear board members and staff,

I have many concerns with the standards, and here are the most critical ones:

1. **Topical Ointment Documentation**: The new requirement for detailed record-keeping of topical ointment use, as per 8VAC20-781-580 A 4, adds unnecessary administrative burden. It risks reducing the use of essential care products like sunscreen or lotion due to the cumbersome process of logging every application. Proposal: Simplify documentation within their daily reports to include only instances of errors or adverse reactions, especially for infants.

2. **Supervision of Older Children**: The revised 8VAC20-781-270 F supervisory standards are overly restrictive, limiting older children’s autonomy to perform simple tasks like visiting hallway cubbies. Proposal: Adopt language allowing short periods of sound-only supervision for preschoolers and timed unsupervised functions within a safe environment for school-age children, fostering independence while ensuring safety.

3. **Age Mixing in Outdoor Play**: The prohibition against mixed-age outdoor play, as addressed in 8VAC20-781-240 G, negatively impacts outdoor time and potentially limits care options for two-year-olds. Proposal: Allow centers to develop playground safety plans detailing age integration strategies, ensuring all ages can safely access outdoor play, focusing on enabling sibling interaction.

4. **Visual Media Restrictions**: The existing restrictions on screen time, as per 8VAC20-781-320 C, do not sufficiently protect toddlers and preschoolers from excessive screen use. Proposal: Prohibit screen time for children under two and limit exposure to no more than 30 minutes per day for older children, ensuring content details are documented and shared with families.

5. **State-Sponsored Orientation Training Issues**: The current training outlined in 8VAC20-781-140 A is outdated, costly, and includes irrelevant content. Proposal: Utilize the training specified in 8VAC20-781-140 D for all staff, removing inefficient requirements and more accurately reflecting actual Virginia standards.

6. **Reptile Restrictions**: According to 8VAC20-781-660 C, the ban on reptile pets in childcare settings deprives children of valuable learning experiences. Proposal: Revise the standard to allow classroom reptiles under proper safety protocols, enhancing educational opportunities.

7. **Inclusion of Naloxone**: The omission of Naloxone as an allowable medication overlooks its life-saving potential in overdose situations. Proposal: Authorize trained staff to have Naloxone available, aligning with CPR and First Aid standards, to ensure emergency preparedness.