8VAC20-781-10 Definitions

"Incident" means an event in which a child is injured or in a situation where injury is likely to occur.

• Please rewrite this for clarity. How is likely to occur measured and what are the standards used?

8VAC20-781-40 Required policies and procedures

A. The licensee shall develop and implement the following written policies and procedures:

• The licensees will be required to write 21 policies stating that they will do what the standards require and then to write 21 procedures to explain the how-to and the methods used to accomplish the policies. While some of the policies and procedures were required before, most are new or have expanded requirements.
• This is a hardship for an already overworked administration and staff, many without experience in writing policy manuals.
• I request that not all policies require written procedures.
•  § 22.1-289.059 and  § 22.1-289.057 of the Code of Virginia only require written policies. This is all these standards should require.

8VAC20-781-90 Health provisions

B. Physical examinations.

1. The center shall obtain documentation of a report from a qualified licensed physician, or a licensed nurse practitioner or licensed physician assistant acting under the supervision of a licensed physician, of a comprehensive physical examination performed within...

• Please define comprehensive. Without definition it is left to interpretation and can become a financial hardship for parents.

8VAC20-781-110 Director responsibilities

A. A center shall ensure that the director is on premises at least 50% of the center’s hours of operation each week.

• Please rewrite for clarification and delete each week. As written, this will mean a center is in violation if the director is out sick or on vacation for a few days.

8VAC20-781-230 Hazardous substances and other harmful agents

D. Hazardous items.

1. Empty plastic bags large enough for a child’s head to fit inside, disposable gloves, and rubber or latex balloons shall be inaccessible to children under three years of age;

• Please make an exception for disposable gloves worn by staff.

8VAC20-781-280 Staff-to-children ratio and group size requirements

A. The maximum group size limitations whenever children are in care.

5. School age eligible through 12 years  100

B. The staff-to-children ratios required whenever children are in care.

5.  School age eligible through 12 years  1:20.

• Please consider the health and safety of children and lower the ratio and group size for school age children.
• One staff member with 20 children ages 5 through 12 (kindergarten-6^th grade) is not enough for proper care. Having 100 of these children in one group setting creates a safety issue when 5-year-olds play with 12-year-olds on an ongoing basis.
• I suggest 1) maintaining the previous ratio of 1:18 for School age eligible up to age nine, or 2) School age eligible through 12 years  1:15

I. If a child with a special need is assigned to a more appropriate age group for the child’s developmental level, a written assessment by a recognized agency or professional shall be required at least annually. These assignments are intended to be a permanent new group and staff members for the child.

• A written assessment by an agency or professional may take weeks or months to secure and is an unnecessary expense for parents.
• The parents and center should be competent to make this decision, so please

8VAC20-781-400 Parental engagement

Before the child's first day of attending parents shall be notified about how to access the following:

3. Description of established lines of authority for staff;

• Please change or read “Description of or position and name of established lines of authority for staff”

8VAC20-781-430 Equipment and materials

D. The following cloth items shall be washable: stuffed animals, cloth dolls, and dress-up clothes; floor pillows shall be washable or have removable covers that are machine washable. The center shall wash stuffed animals, cloth dolls, dress-up clothes, and pillows or removable covers at least once a week or when soiled.

• Requiring these items to be washed weekly will create a financial hardship for centers that do not have washing machines on site. To perform the task weekly will also be a hardship for staff who should be spending their time caring for children.
• Parents often bring in ‘sleep buddies’ for their children which are not washable. Will the center be cited in those cases?
• Please eliminate this standard.

8VAC20-781-500 Diapering and toileting

G. Disposable diapers and disposable training pants shall be disposed in a covered leakproof or plastic-lined storage system that is either foot-operated or used in such a way that neither the staff member's hand nor the soiled diaper touches an exterior surface of the storage system during disposal.

H. When cloth diapers are used, a separate covered leakproof storage system as specified in subsection G of this section shall be used for each individual child.

• This will cause centers to ban cloth diapers in their centers.

J. The storage system required in subsections G and H of this section shall be cleaned and sanitized daily.

• These containers are plastic lined and covered. Please change daily to weekly or more frequently as needed.

8VAC20-781-580 Topical skin products

A. When topical skin products such as lip balm, hand lotion, sunscreen, diaper ointment and lotion, and insect repellent are administered by the center, the following requirements shall be met:

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.

• Asking the staff to record the time that sunscreen, diaper cream and other items are used is unnecessary. The parents have already given permission for the product to be used and expect the center to use them as necessary. Increased paperwork may prevent the application of needed products.
• Please eliminate the date and time of use.

8VAC20-781-610 Emergency response drills

A. All emergency response drills shall be practiced:

1. In each building used by children;

• Please clarify. Does this mean that in each building the required number of drills are to be conducted? If classrooms, cafeteria, and gym are in separate buildings that will mean a total of 36 evacuations conducted per year.

8VAC20-781-620 Nutrition and food services

K. Staff shall be present in the feeding area with children anytime children are eating.

• Please make an exception when children are fed in the classroom or similar area.
• Staff may allow children who are finished eating to go to a play area or a restroom that is immediately adjacent to the eating area. The staff can maintain the sight and sound of children who are eating while still supervising other children.

L. Children shall not be allowed to eat or drink while walking, running, playing, lying down, or riding in vehicles.

• This will eliminate children being allowed to drink from water bottles when on field trips.

8VAC20-781-660 Animals and pets

A. Animals that are kept on the premises of the center or that interact with children at the center shall be vaccinated if applicable.

• What about show-and-tell or when parents unexpectedly bring their child’s pet by the center?