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The table below shows comments received at this web site about the following rule:

New Licensing Rules
Intent sections of aligned licensing rules that will replace current center and family home child care rules, chapters 170-295 and 170-296A. Weights that appear with the rules are only informational ... there is more work to be done before weights are finalized.

DEL uses these comments, and other input during the rule making process, to help us write and adopt the permanent rules. For proposed rules only, DEL will prepare one response to all of the comments received, in what is called a “concise explanatory statement” required by RCW 34.05.325. The department sends the concise explanatory statement to everyone who commented or testified on the proposed rule, and to anyone who asks for it.

Agree/Disagree: Disagree

Comment: The Rule Changes: I fear that these rule changes will do lasting damage to our state’s child care system and will make childcare more expensive and harder to find for our state’s families. The new rules will cost centers substantially in terms of money and administrative time for both improvements to indoor and outdoor space and in additional staffing needs. The new rules will also require a complete reworking of policies and records and training for administration and staff. I hope that child care licensing will offer templates and support in developing all of these. It seems like an insurmountable task to fulfill. I expect that there will be many small centers and family home child cares that will close rather than rework their whole systems. I know that people nearing retirement age will seriously consider whether it is worth it to continue. I also expect that the new ECE and education requirements will deter new people from entering the workforce as child care providers. Many centers will convert to half-day preschool classes to avoid licensing concerns and costs all together. That will be a loss for families needing care for children. There needs to be financial support for the new education requirements. There also should be substantial increases in the amount the state pays for low income children so that centers don’t take a loss for each state paid child that they enroll. Our center doesn’t enroll state paid clients because the reimbursement is so low. There was a significant loss of licensed child care during the recent 2008 economic downturn. These new rules will again make it harder for businesses that struggle to make a profit and teachers and staff that struggle to make a living in this field. Early learning providers are some of the most sacrificing and dedicated professionals, but they are rewarded with some of the lowest wages and worst benefits of any profession. These new rules need to be carefully considered before implementation so that they do not further damage our state’s child care programs.

Date Submitted: 6/27/2018 11:16:41 PM

Agree/Disagree: Disagree

Comment: INTENT AND AUTHORITY I thought that the Legislature gave DEL the job of aligning the WACs governing Child Care, Early Achievers and ECEAP. Minimum licensing requirements were to provide a minimum level of safety for children. Early Achievers builds on the minimum setting high quality and best practice standards (both of which have reasonable people can disagree on). ECAEP was to be the highest level of services to children in need of them, i.e.: those living in poverty. This is not what you have done. You have seriously overstepped you authority in a bureaucratic power grab that puts the needs of a bureaucracy above the needs of children and the providers caring for them. DEL has become a threat to children by potentially putting providers out of business that don’t want to be burdened by pointless paper work, overly intrusive and costly regulations or be forced to follow WACs that we personally believe are harmful to children. Your economic analysis is flawed. Child Cares exist on a very slim margin of profitability. Any increase in cost will put people out of business. We already face huge cost increases due to Washington’s minimum wage increase and paid leave. Those of us providing services in poor rural parts of the State, where majority of children enrolled are on WCCC, are struggling. The State has failed to increase rates to keep up with expenses, many of them mandated by the State. We can’t increase rates to private pay families, nor should they have to subsidize children on State rates. These families already pay taxes. Increased costs put providers out of business. Increased private child care rates push families to unlicensed care. Lack of licensed facilities only leaves unlicensed care. I think most of us agree that unlicensed care can place children in very unsafe situations. I believe many of these proposed WACs are best practice and I strive to help my teachers reach these goals. But let’s be honest how enforceable are many of WACs by a licensing agency that only has time for a once a year visit that may only last 2-3 hours. Where the licensor is not required to have any ECE training or education before being hired. Licensors should have to meet the same standards as Program Directors before being hired. DEL you have failed the children of Washington State. Which is real shame considering the time and money invested in this rules alignment.

Date Submitted: 6/27/2018 10:32:21 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0340 and 0486 Expulsion I understand the state’s position on expulsion, but center staff and administration have to be able to respond to rapidly developing situations that risk harming others children or risk disruption and upheaval to the classroom and center. There are times when a child may not create a dangerous situation but instead creates a disruption and has needs that require one on one supervision in order to remain in the class. If it just isn’t a good fit for child and program, the center needs to have the ability to separate the child and the program. I hope the state will provide templates for centers to develop the policies that they require.

Date Submitted: 6/27/2018 10:29:57 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: They are unduly burdensome, They are difficult to navigate, They stifle cultural and economic equity, They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources. We do not need someone to regulate our every move. We know how to run our own businesses.

Date Submitted: 6/27/2018 9:47:00 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: • They are unduly burdensome, • They are difficult to navigate, • They stifle cultural and economic equity, • They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, • The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources.

Date Submitted: 6/27/2018 6:35:46 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: • They are unduly burdensome, • They are difficult to navigate, • They stifle cultural and economic equity, • They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, • The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources.

Date Submitted: 6/27/2018 6:33:00 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: • They are unduly burdensome, • They are difficult to navigate, • They stifle cultural and economic equity, • They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, • The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources.

Date Submitted: 6/27/2018 6:32:19 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0105. (b) A family home licensee must meet the following qualifica-tions: (i) Family home licensees must have an ECE initial certificate, or equivalent as approved and verified in the electronic workforce registry by the department within five years of the date this section becomes effective; and (ii) Upon completion of the ECE initial certificate or equiva-lent, family home licensees must complete an ECE short certificate or equivalent within two years, as approved and verified in the electron-ic workforce registry by the department. THIS IS RIDICULOUS! ECE DEGREE TO BE A CHILDCARE PROVIDER? HOW DO YOU THINK THOSE PROVIDERS WHO STRUGGLE WITH EVEN COMPUTER WORK ARE GOING TO MAKE THIS HAPPEN? WHAT ABOUT PROVIDERS WITH YOUNG CHILDREN OF THEIR OWN? HOW ARE THEY GOING TO RUN A BUSINESS, CARE FOR THEIR FAMILY AND GO TO SCHOOL? THE FINANCIAL BURDEN ALONE IS ENOUGH TO PUT SOMEONE OUT OF BUSINESS... NOT TO MENTION THE TIME SPENT. ONCE AGAIN YOU ARE FORCING US TO STOP CARING FOR THE KIDS SO WE CAN BE MORE EDUCATED FOR THE KIDS. REALLY? AFTER 22 YEARS OF BEING LICENSED YOU THINK THERE WOULD BE A WAY TO BE GRANDFATHERED IN. THIS WAS HAS GOT TO GO!!!!!

Date Submitted: 6/27/2018 3:40:59 PM

Agree/Disagree: Disagree

Comment: (d) Give families opportunities to share their language and cul-ture in the early learning program; WILL BACKGROUND CHECKS BE REQUIRED OF THESE FAMILIES?

Date Submitted: 6/27/2018 3:26:51 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0085 PROVIDERS ARE NOT QUALIFIED FOR THIS. WE ARE CAREGIVERS. NOR SHOULD WE BE FORCED TO GO BACK TO SCHOOL TO GET A DEGREE TO CARE FOR CHILDREN THIS YOUNG. WHAT ABOUT THIS ONE: (b) Communicate the importance of regular attendance for the child; THIS ISN'T SCHOOL. PARENTS SHOULD NOT BE STRESSED ABOUT GETTING THEIR CHILD TO DAYCARE. KIDS SHOULD BE HOME SPENDING TIME WITH PARENTS EVERY CHANCE THEY GET. FAMILY IS WHAT MATTERS!

Date Submitted: 6/27/2018 3:23:26 PM

Agree/Disagree: Disagree

Comment: (g) Cribs, play pens, bassinets, infant beds, and indoor climbing structures must not be placed next to windows, to prevent harm from shattered glass, unless the window is made of safety glass. THIS NEEDS CLARIFICATION. HOW FAR AWAY? WHY IS THIS GLASS WINDOW BREAKING? IN 22 YEARS OF BEING LICENSED I HAVE NEVER HAD A WINDOW BREAK.

Date Submitted: 6/27/2018 1:38:54 PM

Agree/Disagree: Disagree

Comment: 0285 toddlers should not be in most of this wac. Drs and feeding specialists encourage weaning babies off the bottle by 1 yr of age. Toddlers should be able to hold their own bottle if they chose to do so.

Date Submitted: 6/27/2018 1:29:05 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0146 (3) Prior to construction of new handmade playground equipment, the provider must notify the department and have plans and a materials list available upon request. WHY? IS DEL NOW A CONTRACTOR WHO CAN APPROVE A PLAN?

Date Submitted: 6/27/2018 1:23:47 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0475 Duty to protect children and report incidents. (1) Pursuant to RCW 26.44.030, when an early learning provider has reasonable cause to believe that a child has suffered abuse or ne-glect, that provider must report such incident, or cause a report to be made, to the proper law enforcement agency or the department. what happened to CPS?

Date Submitted: 6/27/2018 1:15:44 PM

Agree/Disagree: Disagree

Comment: 0285 #2b Toddlers should not be fed on demand. Doctors don't agree to feeding on demand for toddlers.Infants yes. Scheduled times for snacks and meals work best for toddlers.

Date Submitted: 6/27/2018 1:13:33 PM

Agree/Disagree: Disagree

Comment: 0285 #2 i In FCC this is not always possible to have a space set up for breast feeding. Parents want privacy and providers may not have the space. Other families in care may not want feeding breast fed children in front of their children. I feel this is also important that they have that right for their children's privacy. ii this is not a providers job to provide info. This should be between the parent and their doctor/breast feeding specialist.

Date Submitted: 6/27/2018 1:02:47 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0145 (12) Outdoor play areas must have two exits that must not be par-tially or entirely blocked, with at least one exit located away from the building. AWAY FROM THE BUILDING? MOST HOUSE GATES DON'T OPEN UP INTO THE NEIGHBORS YARD. MOST GATES (LIKE MINE) OPEN UP TO THE SIDE OF THE YARD BUT THAT ISN'T AWAY FROM THE BUILDING.

Date Submitted: 6/27/2018 1:01:21 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0145 (11) Within six months of the date this section becomes effective or prior to licensing, exiting mechanisms on gates from a licensed outdoor play area to unlicensed space must be equipped with a self-closing and self-latching mechanism (shuts automatically when released from an individual's control). A gate that is not an emergency exit must be locked or self-closing and self-latching. SO A GATE THAT IS AN EMERGENCY EXIT DOES NOT NEED A SELF CLOSING AND SELF LATCHING MECHANISM?? THE FIRST TWO LINES SAYS IT DOES... LAST LINE SAYS IT DOESN'T. THIS JUST OPENS UP THIS WAC FOR INTERPRETATION FROM THE ROTATING LICENSORS WE WILL BE SUBJECT TO.

Date Submitted: 6/27/2018 12:57:44 PM

Agree/Disagree: Disagree

Comment: 0281 #3 provider should also be able to discard unused milk instead of giving back to parent.

Date Submitted: 6/27/2018 12:50:30 PM

Agree/Disagree: Disagree

Comment: 0280 A provider should not have to label all bottles if that is the only bottle fed child in care. A provider should be allowed to have a system to know who has which bottles besides names. Bottle brand, colored bottles, colored baskets, labeled bag in refrig etc . Names don't stay on bottles when cleaned so often.

Date Submitted: 6/27/2018 12:45:30 PM

Agree/Disagree: Disagree

Comment: 0001-4 It is understandable that DCYF will have the ability to monitor programs at any time. However, the wording of this time table is too ambiguous. Having DCYF staff in our programs is disruptive. Creating approximate timetables would be more helpful. Another option would be making internal DCYF licensing and enforcement procedures easily accessible.

Date Submitted: 6/27/2018 10:35:54 AM

Agree/Disagree: Disagree

Comment: 0480 3(g) Assure the driver has a valid driver's license for the type of vehicle being driven and a safe driving record for at least the last five years; What does a 'safe driving record' mean? How would we know what a staff person does on their own time? Tickets ok? No tickets? Accident that is not their fault??

Date Submitted: 6/27/2018 9:40:31 AM

Agree/Disagree: Disagree

Comment: ARE YOU KIDDING ME!!! 04801 3(f) Assure the vehicle has emergency reflective triangles or other devices to alert other drivers of an emergency; TRIANGLES!! These are not necessary. Our hazards lights are enough. OVER-REACHING again!!

Date Submitted: 6/27/2018 9:35:02 AM

Agree/Disagree: Disagree

Comment: 0470 4(d) Drills must be recorded on a department form and include:.... Then your form better be correct. I had to create a completely different form because your current form does not meet WAC as written now. You have added addition requirements in these rewrites...so, you better make it right or give us the right to create our own forms so we can be compliant.

Date Submitted: 6/27/2018 7:11:57 AM

Agree/Disagree: Disagree

Comment: I do follow the rules set. When will all these rules stop. Tell me why a staff member can not start if they are not ever left alone with the children. We have had background checks take months to come through. What will the world be like for children without water play, fingers in dirt planting... We do wash our hand it seems like a 100 times a day.

Date Submitted: 6/26/2018 4:03:17 PM

Agree/Disagree: Disagree

Comment: REMOVE 0455 3(b) The number of children in each classroom or family home program; This is not necessary for family homes....you can tell by the sign in/out sheets. The attendance changes on a regular basis....why do we need to write the number of children?? it will change every 15 minutes until 9am and then again 12 and then again every time a child leaves. I have a long list of just things you want us to clean... we do not have time to rite down the number of children every 15 minutes.

Date Submitted: 6/26/2018 3:38:48 PM

Agree/Disagree: Disagree

Comment: 0265 #8b if a provider has sufficient space to nap, why do they NEED to be placed this way? If there is one cot on each wall of a room, why can't their heads be at the same end? This is not needed.

Date Submitted: 6/26/2018 2:55:11 PM

Agree/Disagree: Disagree

Comment: 0440 8 You guys have really made it easy for you to close, modify a license or put a provider on probation. With the way this is written, you can do what ever you want for what ever reason you see fit. Shame on you for holding our futures in your hands and not letting us prosper.

Date Submitted: 6/26/2018 9:33:27 AM

Agree/Disagree: Disagree

Comment: The intent of DEL appears to be the destruction of an entire industry on which parents depend so they can go to work. Providers are not compelled to stay in child care or early learning careers nor are they compelled to sustain a business at a financial loss nor are they compelled to sacrifice family and personal time to try to appease a state agency constantly escalating the regulatory burden. There are many other opportunities to pursue and thousands of providers have already done so and where have the thousands of children not in licensed care gone to while parents work?

Date Submitted: 6/25/2018 10:48:45 PM

Agree/Disagree: Disagree

Comment: How did we get from licensing and certifying for the health and safely of children in out of home care to "foundational standards" with an incredible increase in the direct costs, administration, and bureaucracy of child care? This is such a regulatory overreach and an attempt to alter reality for families who are simply trying to have their children taken care of by loving, responsible providers at a cost they can afford. The state wanting to build a system and expand its prestige doesn't change the economic realities of parenthood.

Date Submitted: 6/25/2018 4:56:39 PM

Agree/Disagree: Disagree

Comment: The diapering section of these wacs is redundant! 2 feet of impervious flooring is not reasonable in a FCC setting. A mat of sufficient size should be acceptable. These wacs will force FCC providers to close or stop providing care to children in diapers. Providers can't afford to change all their flooring to non carpet.

Date Submitted: 6/25/2018 2:17:38 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0350 Supervising children during water activities. (1) During water activities, an early learning provider must meet all supervision requirements of this section and WAC 170-300-0345. Weight NA (2) During water activities, an early learning provider must: (a) Ensure a one-to-one (1:1) staff-to-child ratio for infants; (b) Hold or have continuous touch of infants, nonambulatory toddlers, and children with special needs as required; This is impossible to comply with. a inch of water for a sitting infant is safe when they are within reach. I understand if the water is deeper that an inch or two. You will be taking away important activity for children. Sitting infants can safely splash in a small tray of water to keep cool.

Date Submitted: 6/25/2018 1:05:42 PM

Agree/Disagree: Disagree

Comment: 0345(4) An early learning program staff member may undertake other activities for a temporary time period when not required to be providing active supervision required under subsection (5)(c) of this section. Such activities include, but are not limited to, cleaning up after an activity or preparing items for a new activity. This early learning staff member must remain in visual or auditory range, and be available and able to respond if needed. Weight #7----what about a home provider that works by themselves? when are they supposed to use the bathroom? Every home provider will break this WAC and a weight of 7 could warrant a closure. This need to be reworded so providers can use the bathroom.

Date Submitted: 6/25/2018 12:58:45 PM

Agree/Disagree: Disagree

Comment: 0200 #2 This wac should be eliminated! towels used after washing hands, should be discarded in a container in the bathroom. This should not be INACCESSIBLE. Children need to be able to wash their own hands and throw towels into a container on their own. How will they be able to do this with used towels being inaccessible?

Date Submitted: 6/25/2018 12:56:03 PM

Agree/Disagree: Disagree

Comment: You are drowning us in paper work. Childcare curriculum should be guided by the children...there is NO WAY a provider can predict what will happen...let alone plan for it. WAC 170-300-0305 Curriculum philosophy and planning. (1) An early learning provider must have a written curriculum philosophy that de-scribes the program of planned daily activities related to early childhood or child development. (2) The curriculum philosophy must address all age groups being served, be informed by the Washington state early learning and devel-opment guidelines, and may include: (a) How children develop emotionally, socially, cognitively, and physically; (b) What early learning looks like or areas of focus for each age group being served; (c) How the provider will meet cultural, dual language learner, and special needs of children in care; (d) How to guide learning and social interactions; (e) The importance of play to a child's learning process; and (f) For infants and toddlers, the importance of developing con-sistent, nurturing relationships with caregivers as a component of learning.

Date Submitted: 6/25/2018 9:55:04 AM

Agree/Disagree: Disagree

Comment: 0195 #4b Providers should not be required to sit with the children for meals. Should state, when possible. Providers may be doing many things to help children, feed babies etc. This is not always possible when providers work alone.

Date Submitted: 6/25/2018 9:04:45 AM

Agree/Disagree: Disagree

Comment: 0185 All that is needed is to require providers to go by the USDA guidlines.

Date Submitted: 6/25/2018 8:49:22 AM

Agree/Disagree: Disagree

Comment: 0175 #3 This is just wrong!!!! If providers can use other pools, unfiltered pools should be allowed as long as they are cleaned and sanitized! This is important to have multiple ways to offer water play. We need to be able to teach water safety to children. Please don't take our pools away!!!

Date Submitted: 6/25/2018 8:45:05 AM

Agree/Disagree: Disagree

Comment: Free standing lamps have to be secured to prevent tipping? This wac limits fcc providers on how they will be able to use their homes/childcare space. It will ruin the homes flooring or end table or what ever it is secured to. So sad we have to damage our homes to comply.

Date Submitted: 6/21/2018 1:01:51 PM

Agree/Disagree: Disagree

Comment: 0135 #2g this is impossible to comply with in fcc. We have a huge age range and all materials can't be at the child's height to reach on their own. For the safety of all the children, plus the fcc may not have enough room to have all the materials out for children at all times. We Need to rotate toys!!!

Date Submitted: 6/19/2018 3:03:10 PM

Agree/Disagree: Disagree

Comment: 0135 #2d placing items in a way that does not interfere with other play equipment. What does this mean? If fcc has limited space, this may not be possible at all times.

Date Submitted: 6/19/2018 2:47:57 PM

Agree/Disagree: Disagree

Comment: 0130 #3 space is sometimes limited in FCC. This wac may not always be possible. Just as in real world interactions, there needs to be ways to work around your fellow friends/fellow workers.

Date Submitted: 6/19/2018 2:17:33 PM

Agree/Disagree: Disagree

Comment: 0107 This training should be available by many sources, not just collage classes! Please let other agencies offer classes. Most providers work very long hours and can't attend college classes without closing during that time to receive this training. This will close FCC providers down.

Date Submitted: 6/19/2018 1:19:55 PM

Agree/Disagree: Disagree

Comment: 0106 All this training will put providers out of business. Where does taking care of the children come in? Basic entry level training should be required, not this much all at once.

Date Submitted: 6/19/2018 1:05:11 PM

Agree/Disagree: Disagree

Comment: 0100 any and all equivalent requirements NEED to be known before agreeing to this. This requirement will put many providers out of business.

Date Submitted: 6/19/2018 12:53:28 PM

Agree/Disagree: Disagree

Comment: All of these changes seem great in theory, but have any of them been proposed by people who have actually worked in a child care center? Many of the items don't even seem feasible. How are we (as childcare centers) supposed to find people to hire quickly when we are short staffed? Background checks can take weeks to go through, AND I have found, they don't share information that the employer really should know, such as past CPS cases. Why are the powers-that-be messing with the system that works perfectly fine the way it is?

Date Submitted: 6/13/2018 3:13:24 PM

Agree/Disagree: Disagree

Comment: 0100 staff should have reasonable time frames after hiring to get qualifications done. If not, this will put fcc out of business.

Date Submitted: 6/12/2018 2:39:24 PM

Agree/Disagree: Disagree

Comment: 0085 this along with all the extra paperwork will put providers that work alone out of business. This will be paperwork instead of loving/being/working with children.

Date Submitted: 6/12/2018 2:33:36 PM

Agree/Disagree: Neutral

Comment: 0065 What does school readiness materials mean? Every year? So from birth thru 5 yrs? This is not age appropriate!

Date Submitted: 6/12/2018 1:43:27 PM

Agree/Disagree: Disagree

Comment: 0240 2(e) If a bleach solution is used for sanitizing or disinfecting, an early learning provider must use one that is fragrance-free and follow department of health's current guidelines for mixing bleach solutions for child care and similar environments. Bleach is bleach...who cares if it is scented...bleach has it own scent. This is stupid...just be grateful that we are suing it.

Date Submitted: 6/11/2018 10:45:41 AM

Agree/Disagree: Disagree

Comment: It is just not feasible to maintain ratios when a person can't work until they are cleared!

Date Submitted: 6/8/2018 2:09:21 PM

Agree/Disagree: Disagree

Comment: requiring a background clearance before employment begins will leave countless amounts of providers without teacher and likely force them to close temporarily while waiting for the paperwork to process. It's not a quick process, and sometimes we have people quit with no notice, it takes months to hire a qualified person. I understand not leaving them alone with children, but not having them in headcount at all is not going to work.

Date Submitted: 6/8/2018 1:59:40 PM

Agree/Disagree: Disagree

Comment: There should not be an exemption for providers who operate less than 4 hours. All providers who care for children in the required age range should be required to follow the same regulations. What is happening now and will be worse once these new rules are in place, is that as the costs grow for licensed providers parents will unknowingly choose unlicensed, possibly illegal operators because they are cheaper, which will put an increasing number of children at risk. The state is over-regulating only a portion of the same market such which will drive children into unlicensed, potentially illegal childcare situations. If the state instead made the rules more reasonable and then applied them to everyone children overall would be safer in our state.

Date Submitted: 6/8/2018 1:26:29 PM

Agree/Disagree: Disagree

Comment: Disagree, again more rules that DEL wants to enforce that they don't even do in their own homes or environments. Let's get real people. People want there babies cared for and loved. not us working on paperwork and major changes to our environment. Let's get back to the real reason we do this....for the children. to love and nurture. NOT THE DAMN RULES THEY WANT US TO FOLLOW

Date Submitted: 6/8/2018 12:50:43 PM

Agree/Disagree: Disagree

Comment: Need to keep the age at 18 months and not age 2. There is going to be a continual shortage of daycare available in the area and this is not going to help. Again DEL has no idea and does not care about the shortage.

Date Submitted: 6/8/2018 12:41:58 PM

Agree/Disagree: Disagree

Comment: (iv) Be on moisture resistant, washable material that horizontally or vertically surrounds and extends at least two feet from the diaper changing station and hand washing area; and(v) Be uncluttered and not used for storage of any items not used in diapering a child. In a family home environment. Two feet of surroundings to store diapers for 2 children is too much to ask. My bathroom is too small to have nothing within 2 feet of the changing table. Is DEL going to close providers if they can't comply when for years it has been fine the way it is?

Date Submitted: 6/8/2018 10:38:17 AM

Agree/Disagree: Disagree

Comment: 0185(2) An early learning provider must serve a fruit or vegetable as one of the two required components during at least one snack per day. Where do you (DEL) get the right to override the USDA food program and require us comply with this rule. USDA guidelines should be followed not DEL's agenda.

Date Submitted: 6/7/2018 9:49:12 AM

Agree/Disagree: Disagree

Comment: 0350(4) For water activities on or off the early learning program premises, where the water is more than twenty-four inches deep, an early learning provider must ensure: (a) A certified lifeguard is present and on duty; and (b) At least one additional staff member than would otherwise be required is present to help actively supervise if the children are preschool age or older. This should not be followed if all the children present are participating in lessons.

Date Submitted: 6/7/2018 9:43:50 AM

Agree/Disagree: Disagree

Comment: Too much interference and not enough finding out exactly what a provider can or cannot do.

Date Submitted: 6/6/2018 4:17:45 PM

Agree/Disagree: Disagree

Comment: No comment

Date Submitted: 6/4/2018 12:48:59 PM

Agree/Disagree: Disagree

Comment: The outside activity time lines are not reality based. We can have a plan for the day to play outside in the afternoon and then it begins to rain. Are we supposed to take them out anyways (including infants) and subject them to the bad weather? Current WAC is sufficient and providers will always opt for more outside time when the weather is approximate. You do not have to make it so that every three hours we have to take them outside for 30 minutes.

Date Submitted: 6/1/2018 10:43:58 AM

Agree/Disagree: Disagree

Comment: for Family home providers, the age needs to remain 18 months. Moving it back to 2 years will only force another/continued shortage on infant care. It is difficult to find care for infants and that is why family home bargained to lower the age to 18months (just for family homes) so this would open up spots for infants that desperately need care. This will force providers to terminate care for some of the children they currently care for. Please move age limits back to 18month and not 2 years.

Date Submitted: 6/1/2018 10:29:02 AM

Agree/Disagree: Disagree

Comment: 0350(4) For water activities on or off the early learning program premises, where the water is more than twenty-four inches deep, an early learning provider must ensure: (a) A certified lifeguard is present and on duty; and (b) At least one additional staff member than would otherwise be required is present to help actively supervise if the children are preschool age or older. This will eliminate a provider working alone to take their children to swimming lessons. There are multiple life guards (they teach the classes)present. This is an important life lesson I am happy to offer the children in my care and I do not need to pay an additional person to be there. There are at least 10 life guards present. There is no need to additional help when all the children are in the water with a life guard...This rule puts more children in harms way because they will not be able to get the lessons they are entitled to all because I don't have additional staff. This should only if there are children not participating in the lessons. If they are all in the water a second person is not needed.

Date Submitted: 6/1/2018 10:03:29 AM

Agree/Disagree: Disagree

Comment: 0245 Laundry and equipment. (1) Laundry and laundry equipment at an early learning program must be inaccessible to children.. my laundry machines are located in my only bathroom. This is impossible. Are you going to shut me down?

Date Submitted: 5/29/2018 9:56:49 AM

Agree/Disagree: Disagree

Comment: 0230 1(f) Have sufficient supplies for the number of enrolled children and staff consistent with the early learning program's licensed capacity, Please clarify...what is sufficient?? If I am licensed for 12 and there is myself and an assistant does that mean I must have 14 of each item listed?

Date Submitted: 5/24/2018 9:45:15 AM

Agree/Disagree: Disagree

Comment: 0241(14) Children must not: (a) Be present when carpets are cleaned or vacuumed unless the provider is spot vacuuming, the vacuum has a HEPA filter, and children are not within the immediate area; Carpet cleaning (wet) I can see. We could simply place a dry towel over it until later....BUT VACUUM??? What if a provider works by themselves and someone spills glitter....are we supposed to leave it just because the children are in the immediate area? Would you then write us up because we removed the children for the area and not supervising them while we 'spot vacuum'? The children need to be supervised and getting used to the sound of a vacuum is a life lesson that needs to be gained....they can't go the rest of their lives never vacuuming because they are afraid. Vacuuming section of this rule needs to be removed.

Date Submitted: 5/23/2018 1:13:16 PM

Agree/Disagree: Disagree

Comment: 0225 5(h) Indoor and outdoor play space to be cleaned and disinfected where animal or bird waste or vomit is present. Inside...I understand. How do you disinfect the grass?

Date Submitted: 5/23/2018 10:43:27 AM

Agree/Disagree: Disagree

Comment: 0195 4 (b) Sit with children during meals. This is not always possible to do in a family home. We have infants to feed and cleaning to do. The wording in current WAC should be added: "whenever possible." I would LOVE to sit and eat with the children....but you have made a list a mile long of just cleaning and I won't have time to do it all and sit (let alone eat).

Date Submitted: 5/21/2018 1:09:46 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0186 Food allergies and special dietary needs. (1) An early learning provider must obtain written instructions (the individual care plan) from the child's health care provider and parent or guardian when caring for a child with a known food allergy or special dietary requirement due to a health condition. Individual care plan? Is DEL planning to make this form available?

Date Submitted: 5/21/2018 10:54:55 AM

Agree/Disagree: Disagree

Comment: 0185(2) An early learning provider must serve a fruit or vegetable as one of the two required components during at least one snack per day. This is not required in the USDA Child and Adult Care Food Program (CACFP) Hand-book for all children(unless a child is 6mnth-1year) Why is DEL overstepping their authority and changing what is required by CACFP??

Date Submitted: 5/21/2018 10:50:33 AM

Agree/Disagree: Disagree

Comment: 0180(v) A breakfast or morning snack must be available to children in care. Is this pertaining to overnight care children? It mentions breakfast in (vi)…so why is this here? Some providers do not serve breakfast … the parents feed them before coming….are you forcing providers to feed a child that has already eaten at home?

Date Submitted: 5/21/2018 10:41:09 AM

Agree/Disagree: Disagree

Comment: 0180 (a) Meals and snacks must be served not less than two hours and not more than three hours apart unless the child is asleep; (b) Children in care for five to nine hours: (i) At least one meal and two snacks; or (ii) Two meals and one snack. (c) Children in care for more than nine hours: (i) Two meals and two snacks; or (ii) Three snacks and one meal. Can you please explain where this is in the USDA meal plan/guidelines? Some providers do not serve breakfast …parents feed them. And if they are in our care for 5 hours (8am-1pm), they would only have one snack and one meal within the allotted meal/snack schedule. How do we??...and where do we squeeze in another snack in that time span?? Section (b) needs to be reworded.

Date Submitted: 5/21/2018 10:32:44 AM

Agree/Disagree: Disagree

Comment: 0175 3 Wading pools that do not have a filtering system are not permitted in the early learning program space. Please reconsider allowing wading pools (without filters...less than 24 inches of water)and include current WAC to the sanitization and supervision. Please do not take this important play from children.

Date Submitted: 5/21/2018 10:15:55 AM

Agree/Disagree: Disagree

Comment: 0170(2)....... If a local government agency is not available to conduct a fire safety inspection, a provider must inspect for fire safety using the state fire marshal form. Where is this form?...it should have a link to a form that you are requiring us to fill out.

Date Submitted: 5/21/2018 9:27:56 AM

Agree/Disagree: Disagree

Comment: 0165 (g) Platforms and decks. All platforms and decks used for child care activities must meet local building codes pursuant to RCW 43.216.340 within six months of the date this section becomes effective. This does not include play equipment. All platforms and decks with a drop zone of more than eighteen inches must have guardrails in sections without steps. Are you telling us that we need to replace our decks? Is DEL giving family homes $25,000. That is how much it will cost to replace my deck. REVOME THIS WAC! Unless you want to put family homes out of business.

Date Submitted: 5/17/2018 1:28:10 PM

Agree/Disagree: Disagree

Comment: the letter/numbering in 0165 is incorrect or confusing. Please check.

Date Submitted: 5/17/2018 1:26:03 PM

Agree/Disagree: Disagree

Comment: 0165 f (ii) All stairways (indoor and outdoor), not including play structures, must meet local building codes pursuant to RCW 43.216.340. if our outside stairs met code when they were built and we are not replacing the stairs they should not have meet current code. This could be costly if a providers is forced to replace all stairs. This needs to be 'grandfathered' in and stated when replacing outside stairs...

Date Submitted: 5/17/2018 1:22:33 PM

Agree/Disagree: Disagree

Comment: 0165 c (iii) Free standing lamps must be attached or secured to prevent tipping; And how are we supposed to comply with this in our homes? superglue them to our tables? I understand the need, but they can be arranged in a way that tipping doesn't occur. Put forcing family homes to 'nail down' our lamps to our tables is over-reaching. Will everyone who works for DEL be doing this in their homes? I think not...please reword.

Date Submitted: 5/17/2018 1:18:27 PM

Agree/Disagree: Disagree

Comment: 0165 (d) Safe noise levels. Noise levels must be maintained at a level in which a normal conversation may occur; Did the people actually writing these work in childcare? DEL's going to have to write us all up on this one. Children are noisy from time to time. This needs to be thrown out.

Date Submitted: 5/17/2018 1:12:02 PM

Agree/Disagree: Disagree

Comment: 0165 (d) Making inaccessible to children plastic bags and other suffocation hazard; What are provider to do with soiled clothing? What about trash can liners? It's mandatory use when blood is cleaned up. if we can't use plastic bags then you will have to write us up for not keeping the children safe form feces and blood and not lining our trashcans correctly. Damned if you do, damned if we don't. This needs to be rewritten so the uses of plastic bags can be used when appropriate.

Date Submitted: 5/17/2018 1:03:29 PM

Agree/Disagree: Disagree

Comment: 0147 (2) An early learning provider must dress children for weather conditions during outdoor play time. implies that the PROVIDERS needs to supply the clothing. Parents don't always supply such clothing and we are forces to exclude that child from outside play due to the lack of appropriate supplies. Please reword so provider don't have to supply every child with clothing that we cannot afford to purchase.

Date Submitted: 5/17/2018 7:58:20 AM

Agree/Disagree: Disagree

Comment: 0146 b needs to include the clarifications of "refers to climbing equipment that has a climbing surface of 48 inches or higher." This was clarified when the WAC was first written and the wording has not changed therefor this needs to be added to the wording.

Date Submitted: 5/17/2018 7:52:12 AM

Agree/Disagree: Disagree

Comment: 0145 (12) Outdoor play areas must have two exits that must not be partially or entirely blocked, with at least one exit located away from the building. How can this be complied with? Am I supposed to put a gate between my neighbors yard and mine? Both of my gates are on each side of my house and I have neighbors on each side and behind me? Remove the last statement or you will be putting some family homes out of business...but maybe that is what you want.

Date Submitted: 5/17/2018 7:37:49 AM

Agree/Disagree: Disagree

Comment: 0145(7) Licensed outdoor play areas must be enclosed to deter people without permission from entering the area.??? How is a provider supposed to comply with this WAC? I live on a corner lot. I have a 5 foot fence. I can not stop anyone who would like to jump my fence. Is DEL going to force me to put a 8 foot fence with barbwire around it?? This WAC need to be explained.

Date Submitted: 5/16/2018 3:34:24 PM

Agree/Disagree: Disagree

Comment: 0130 (2) - this does not comply to residential homes. Center's in commercial buildings are required to comply. This will put most of family homes out of business since I have no way of putting in ramps and make my home wheelchair assessable. This needs to include the wording CENTER REQUIREMENT ONLY

Date Submitted: 5/16/2018 1:29:47 PM

Agree/Disagree: Disagree

Comment: How does 0120 have anything to do with the health and safety of children....you are over stepping your authority and telling us things that L&I teaches us?

Date Submitted: 5/16/2018 1:15:48 PM

Agree/Disagree: Disagree

Comment: 170-300-0111 Staff oversight. (a) Establish a work plan with clear expectations; ??? what is this??? how can we establish something that has not description???? REMOVE!!!

Date Submitted: 5/16/2018 1:09:06 PM

Agree/Disagree: Disagree

Comment: 0110 you are burying providers in paperwork. We can write everything out and something can happen that we didn't anticipate and it will make it all none and void.

Date Submitted: 5/16/2018 10:56:23 AM

Agree/Disagree: Disagree

Comment: 0107 is confusing and needs to be simplified. There are so many different trainings that there needs to be a graft with a time line.

Date Submitted: 5/16/2018 10:41:53 AM

Agree/Disagree: Disagree

Comment: MANY of these rules are subjective. Please clearly define terms. Please email me for a .pdf indicating which new regulations are overly subjective in nature, as there are too many to name by specific WAC.

Date Submitted: 5/15/2018 1:31:30 PM

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