8VAC20-781-490 Hand washing

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

1. Before and after:

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

• Why is it necessary to wash hands before if staff use gloves to administer medication? Please delete it if it is not necessary.

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.

• Transition time is often one of the most challenging times of the day and when children need supervision the most. Now teachers are asked to leave children waiting at the room entrance while they wash their hands because they must do it before supervising the children.
• This requires a staff person to wash her hands each time she walks with her children from one room to another, steps into the hallway to speak to a parent, goes out of the room to check on a child using the restroom, etc.
• Not every classroom is equipped with running water, so this poses an additional hardship.
• This standard will be a programmatic hardship for staff who are already required to wash their hands multiple times throughout the day and take time away from children. Please eliminate.