The current standards do not require reporting of topical ointment use in any way. 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”) creates a medication log–like requirement.

That means, for every child, multiple times a day, teachers have to write all of that for sunscreen or if they put lotion on or if they have lip balm. This is requiring medication-like documentation for simple things like hand lotion, which already have to be approved by parents for teachers to apply. This would be an entirely new record keeping system for no real reason. It's a huge administrative burden for teachers. The most likely result if this standard were adopted is that programs would create policies to reduce topical ointments if at all possible, simply to avoid the burden of documentation. This means children would be less likely to have what they need when they have chapped lips, hands, or a diaper rash. There must be a simpler way to meet the need that led to this requirement. Perhaps, for infants, this documentation could be part of their daily documentation. Or perhaps only notifying families if there were errors or adverse reactions. To give you a sense of scale, my program puts sunscreen on 94 children three times a day in the summer—that is 282 new records each day just for sunscreen. Most parents can think of a time when their child had chapped skin and they were using lotion after each handwashing. A provider would be faced with a choice between putting lotion on that child and documenting it 10–12 times a day, refusing to allow lotion due to the documentation burden, or risking a violation for not keeping proper documentation. This regulation would have a dramatic impact and documentation should not be required for topical ointments