Regarding 8VAC20-781-40, it is important to add the phrase "if applicable" to policies that pertain to activities not all centers engage in:  e.g., Swimming; transportation.  If you don't add "if applicable" to the text, centers that do not have a pool and never take children swimming will have to have a written policy and review it - a waste of everyone's time. Likewise, centers that only are licensed to serve preschool aged children and older should not have to orient, train and have policies around Sudden Infant Death Syndrome.  

It would be more reasonable and free up more time for ensuring quality care and staffing if all policies did not have to be reviewed annually.  It makes sense for emergency preparedness; it does not make sense for something like drinking water.  

Finally, it is currently impossible for centers to craft policies around stock epinephrine, as we have been provided no means to access stock epinephrine and no guidance on what the guidelines will around storing and using. Noting child care centers will not all have a nurse on site as a public elementary school might, so any guidance should reflect the reality of actual child care centers in the real world.