Thank you for your serious consideration of public comment on the new proposed standards for licensed care. As you know, affordable and accessible child care is out of reach for so many families in Virginia. This is a crucial moment where you and your agency can work to find a regulatory balance that 1) sharpens helpful and necessary standards that prioritize safety and a quality experience for children, school staff, and teachers 2) eliminates and overhauls outdated or flawed regulations that make teaching and working in schools more difficult with little positive result or safety improvement for children and 3) does not needlessly raise the cost of child care at a time when insufficient subsidies exist to support families and teacher wage increases. To that end, I'd like to highligh a few places to strengthen the proposed standards:

• Please reconsider 8VAC20-781-240 G. Young children can be kept safe on the playground in a mixed age environment. Instead of mandating separation I 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.
• My preschool aged child is 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. 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. (any details needed on what a safe area is could be below).
  (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. (any other details could be added).
• My child uses sunscreen and chapstick 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”) requires far too much documentation for busy teachers. Please allow providers to continue to use parent authorized topical ointments without detailed documentation of each application.
• While the new standards allow for the use of stock epinephrine, they miss an opportunity to allow for the use of Narcan (Naloxone) which is a lifesaving medication. The more of this critically important medication is available in our communities, the more lives will be saved. 

Thank you for reading this and for your consideration.

James Pollard