Thank you for the opportunity to comment on the proposed standards.  I want to highlight some concerns I have about the proposed standards:

1. Revision of sight and sound

My preschool and school aged children are competent to be out of sight or sound supervision for short periods. I trust my child's teachers to scaffold their learning as they build this independence and confidence through tasks such as putting their items in their cubby and moving between rooms on the hallway. Please change 8VAC20-781-270 F to allow children preschool aged and above reasonable freedom of movement at school.

I recommend Virginia adopt this language:

(1) For preschool children, staff must supervise by sight and sound most of the time. Supervision by sound alone is also permissible for short intervals, under five minutes, as long as staff check on children who are out of sight and children are always in a safe area.
(2) For school-age children doing tasks in a safe environment, they may be out of sight and sound supervision for up to ten minutes provided staff are nearby so they can provide immediate intervention if needed.

2. Shared playground space

Please reconsider 8VAC20-781-240 G. Young children can be kept safe on the playground in a mixed age environment, and there is so much learning that occurs in a mixed-age space. Instead of mandating separation we urge regulators to consider adding a policy requirement to 8VAC20-781-40 A 4 playground safety plans. Plans can be made to include policies for how, if, and when different ages will engage together on the playground, how younger children will be kept safe, and how ratios appropriate to the youngest child will be maintained for the group.

3. Documentation of topical ointments

My child uses topical ointments in their early childhood 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. Please allow providers to continue to use parent authorized topical ointments without detailed documentation of each application.

4. Sandbox coverage

The new language of 8VAC20-781-260 requires all sand to be covered when not in use. This is unnecessary for properly draining sandboxes, and impractical for large sand boxes.  I recommend you keep the old language: “Sandboxes with bottoms which prevent drainage shall be covered when not in use.”