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

New Licensing Rules
Environment 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 current Wac's are more than sufficient ...The State is out of control with more regulations...this is NOT Nazi Germany...or is it?Parents and providers are more than able to decide what is needed in special circumstances...our children are NOT wards of the State! What is going on...leave us alone and let the parents and the providers do our jobs!

Date Submitted: 6/27/2018 11:03:10 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 9:37:39 PM

Agree/Disagree: Disagree

Comment: If it's not related to the Health and Safety of children, the state needs to leave environmental decisions to the individual providers.

Date Submitted: 6/27/2018 9:32:09 PM

Agree/Disagree: Disagree

Comment: Leave the environment quality sections to the system the state created - Early Achievers. Minimum Licensing Standards are not "best practice" and the state should not be mandating what they consider best practice. Every program is different and that must be respected. Parent choice is key here - as an example, the Montessori environment is going to look very different than other environments. ECEAP classrooms are filled with new equipment and materials are continually renewed, and community child care centers and family home providers have budgetary restraints that ECEAP does not have to deal with. We are not the same, and quality can look very different.

Date Submitted: 6/27/2018 9:29:54 PM

Agree/Disagree: Disagree

Comment: Environment Many of the WACs in this section are vague and highly subjective in their interpretation. I was hoping the new WACs would be less subjective. DEL does a poor job now in consistency between licensors on the same current WACs. Licensor “A” comes through the building and says everything looks good, Licensor “B” comes through a couple weeks later and writes a 20 page FCLA when there have been no changes in the environment. WAC 170-300-0130 Indoor early learning program space. (3) Early learning program space must allow children to move between areas without disrupting another child's work or play. What does this even mean? I find it vague and highly subjective in its implementation. Depending on the number of children in attendance that day the same space could be flowing well or congested if everyone wants to be in it. WAC 170-300-0135 Routine care, play, learning, relaxation, and comfort. (d) Arranged in a way that does not interfere with other play equipment. Highly subjective and vague. (3) “soft furnishings” may include upholstered furniture I have been forced to remove couches and other upholstered furniture because it was not cleanable. What will the cleaning standard be for soft stuff like couches and such? Frequent cleaning will ruin these items quickly and is expensive. WAC 170-300-0140 Room arrangement, child-related displays, private space, and belongings. (1) encourage independent access by children. What does this mean? I find it a highly subjective standard. (2) related to current activities or curriculum. How does DEL expect licensors to judge if Materials are related to current activities or curriculum? (6) Sufficient space. Please provide a definition that will not be subjective in its interpretation. (6) (b) Move freely. Please provide a definition that will not be subjective in its interpretation. How will this been enforced? WAC 170-300-0145 Outdoor early learning program space. (4) “Outdoor play space must promote a variety of age and developmentally appropriate active play areas for children in care.” This is a poorly ordered sentence. How does space promote areas? (6)So the only alternative to “standard” fencing materials is some type of masonry wall? (8) & (9) overlap and both state a gate can have no gap through which a sphere with a diameter of three and one-half inches can pass. If true would this be two 6 point violations? WAC 170-300-0146 Equipment and surfaces in outdoor early learning space. (3) Handmade playground equipment. Who in DEL has the expertise to evaluate plans for playground equipment? If DEL approves a set of plans and the playground equipment is built to the plan, does DEL assume liability if a child is hurt on that equipment? ACTIVITIES WAC 170-300-0150 Program and activities. (1) & (2) Who at DEL will be making determinations as to how programs and actives meet the requirements in this section. Since DEL licensors don’t currently have to have any ECE credits to be hired to enforce the new WAC or current WAC’s, how are they going to have the expertise to decide if materials, activities, curriculum & environment meet individual, developmental, and cultural needs of children. WAC 170-300-0160 Promoting acceptance of diversity. Again who gets to make the determination of compliance with this WAC? Will there be a checklist of how many book or posters must show diversity. Will a list of book title or photos be provided by DEL? Who gets to be the judge of what constitutes diversity? What qualifies my licensor to make these determinations? Different licensors don’t agree as to what preventing access to unsafe stuff means. Is it up on a shelf out of reach ok or should it be locked in a cabinet or removed from licensed space. I’ve been given all three answers for lotion. WAC 170-300-0165 Safety requirements. (2)(c) No items capable of forming a loop. This should be reconsidered for school age rooms. (e) Fire Arms. Must parents be prevented from coming into the building with a concealed firearm? (3)(g) Poor Condition needs a definition. A couch in poor condition in affluent communities is thrift store gold in poorer communities. (4)(c)(iii) Halogen lamps and bulbs. Why are they being prohibited? (4)(d) Safe noise levels. I am located in an old gymnasium. We have a half basketball court sized indoor play space and four foot walls separating classrooms. If kids are playing in the gym at all, the building is loud. There is no way to fix this. (5)(a) The wording is bad. “In areas accessible to children, tamper-resistant electrical outlets must be used…” tamper-resistant electrical outlet is a technical term that has a legal definition under the uniform building code. WAC 170-300-0170 Fire safety. (3)(g)(ii) Carbon monoxide detectors. Maybe you could mention in this WAC that a fuel-burning appliance, heater, fireplace or have an attached garage must be present for a carbon monoxide detector to be required. IE: there must be source of carbon monoxide. WAC 170-300-0185 Menus, milk, and food. (1) Follow requirements of the USDA Child and Adult Care Food Program (CACFP) Handbook. Why are we required to follow nutrition guidelines that a based on politics instead of the latest nutritional science? (2)Serve a fruit or vegetable at one snack per day. This will result in lots of wasted food and hungry kids. It will also limit options available for snack, there are only a few widely available and affordable fruits and vegetables to serve large programs. It will also increase costs. WAC 170-300-0197 Safe food practices. (4)(e) Food past the "best served by" date must not be served. This is not a food safety date, this is a marking ploy to get Americans to throw out safe food and buy more products. It only means a product might be past its peak flavor are crispness. Not that it will make you sick. HEALTH PRACTICES WAC 170-300-0200 Handwashing and hand sanitizer. (4) Providers and washing hands. Washing my hands 30 to 50 times a day leaves them like sandpaper in the summer and cracked and bleeding in the winter. No amount of lotion helps. (5) Kids washing hands. With the thinner skin on young children, washing hands as frequently as this WAC requires will leave the children’s hand cracked and bleeding. It will also mean spending most of the day in the bathroom supervising hand washing. (6)Hand sanitizer should never be used in child care. Hand sanitizer does not get hands clean. Over use of these antibacterial products leads to the development of super germs resistant to treatment of any kind. WAC 170-300-0241 Cleaning schedules. (9) Diaper receptacles, get new liner if odor is present. It’s a diaper receptacle, when is there not an odor present? When it’s empty. (11)(b) Clean rugs or carpet at least once per month. Cleaning too frequently, especially with chemical solutions, can actually wear down your carpet by loosening the fibers, making the carpet loose and more susceptible to dirt. This is an expensive WAC. It will result in the removal of carpets from infant rooms. WAC 170-300-0255 Pest control. Is DEL encouraging the use of toxic substances in early learning centers? WAC 170-300-0265 Sleep, rest, and equipment. (8)(a) 18 inches on each side. Is that just 18” between two mats or is that 18” for each mat for

Date Submitted: 6/27/2018 8:48:27 PM

Agree/Disagree: Disagree

Comment: 0200-5-g it is understandable that a child should wash their hands after sneezing. However, a provider should not be held accountable if a child sneezes and is unaware of the situation. Ex: If a licensor is on the premises and witnesses sneezing but the provider does not this is a health violation, with a weight, and the provider is held accountable. 0221-2-b-i this requirement is an Early Achievers standard. If a provider needs to always be with a child when a diaper is being changed, an elevated edge is not necessary. Providers are not permitted to use safety belts on changing mats. An elevated edge is the same. It will not prevent a child from rolling off. 0225-2-b the wording needs to be “contagious illness.” Pets can acquire illnesses such as cancer that will not threaten a child’s health and safety. 0230-1-b needs to be eliminated if there is no medication included in the first aid kit. Using the description in section 2 there is no reason this be inaccessible to children. If a provider decides to take children off the premises the first aid kit will be accessible based on the definition in this chapter. 0230-2-k current CPR instruction does not include mouth to mouth resuscitation. It only requires chest compression. 0240-1 providers should not be required to clean and sanitize EVERYTHING on the premises. This would include garages, building exteriors, sidewalks, trees, etc. Refer to the definition of “premises.” 0255. During NRM a team insisted that each section be weighted individually. If that is the case a provider is at risk of a heavy fine and possible closure. I think there should be only one weight for this entire WAC.

Date Submitted: 6/27/2018 7:52:41 PM

Agree/Disagree: Disagree

Comment: 0180-2 “after each meal or snack” is excessive. It should read “after a meal or snack, at least once per day while in care.” If a provider is alone caring for 10 children, ages 3-12, she has the potential of serving 2 snacks and 2 meals in any given day. This translates into 3-4 tooth brushing opportunities in any given day. Providers will not have enough time to facilitate early learning opportunities. This will also take away the opportunity for families to model for children the importance of tooth brushing. Most dentists recommend brushing teeth twice a day. Once at child care is enough. 0185-1-a Family Home programs should not be mandated to have dated menus if they participate in the USDA food program. Menus can change at the last minute depending on food preferences of the children present and number of children in attendance. A sample menu should suffice. 0185-2 This is above and beyond the USDA standards and should be eliminated. 0195-4-b “whenever possible” should be added. In Family Home programs a provider is often working alone. As long as she/he is in the same room during meals and snacks that should meet the need for safety. FH providers must wear multiple hats, and requiring them to sit down with children during meals would translate into the inability to meet all of the children’s needs during a meal, including but not limited to blowing noses without cross contamination. 0200-2 if a provider uses cloth/single use towels only the soiled towels need to be inaccessible to children. The definition of “inaccessible” needs to be amended. If used towels need to be under lock and key how do children take care of their own needs without have access to locking mechanism?

Date Submitted: 6/27/2018 7:17:26 PM

Agree/Disagree: Disagree

Comment: WAC 02555 I disagree with weights on every individual section on this WAC. If a provider finds a pest and does not follow every single step exactly, the weights assigned to each individual section has the possibility of closing a provider down. The weights are punitive and will not produce higher quality programs. This entire WAC is unreasonable. There are bugs, pests, insects everywhere. What could you have been possibly thinking with this proposed WAC? Was NRM held hostage to this WAC? Thank you for your time. William McGunagle

Date Submitted: 6/27/2018 7:10:16 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 6:34:17 PM

Agree/Disagree: Disagree

Comment: 170-300-0180 (2) An early learning provider must offer children the opportunity for developmentally appropriate tooth brushing activities after each meal or snack. Please change "must" to "may". The logistics of offering tooth brushing to every child after every meal and snack is prohibitive. That is something that is done morning and evening in the home.

Date Submitted: 6/27/2018 4:16:48 PM

Agree/Disagree: Disagree

Comment: 170-300-0165 2(d) Making inaccessible to children plastic bags and other suffocation hazards This regulation needs work since bags are used as trash can liners and to hold wet or soiled clothes. The terminology "inaccessible to children" needs to be changed. Additionally, the risk is different for babies/toddlers and preschoolers.

Date Submitted: 6/27/2018 4:06:36 PM

Agree/Disagree: Disagree

Comment: 0260 Toxins, Cleaning Supplies: This proposed is too vague on inaccessible. If we regulated to the notion using the EA definition of accessible to the opposite of inaccessible the cleaning supplies could be potentially accessible. It would still be within a few inches of children and toxins and cleaning supplies are dangerous to children. Medications except rescue medications have to be locked. May I propose for cleaning supplies and toxins that they be LOCKED except for the soap to be used to clean and wash hands and the product that has been pre- made to sanitize and clean. Those 4 items soap to clean and wash hands and the product to be used daily to sanitize and disinfect be allowed to be in license space unlocked but specifically describe how high they have to be to be considered INACESSIBLE.

Date Submitted: 6/27/2018 2:45:45 PM

Agree/Disagree: Disagree

Comment: 0165 There are duplications in some of these sections and 0150. The duplication needs to be noted so there is not a double weight. 0165-2-f unless a window is at floor level visual reminders should not be required. Remember these are our homes in Family Home programs. 0165-3-b This contradicts the WAC that allows providers to have active supervision when children are participating in cooking activities.

Date Submitted: 6/27/2018 1:28:56 PM

Agree/Disagree: Disagree

Comment: 0150-2-f is a duplication of a-e. this is subjective and should not be weighted or it should be eliminated.

Date Submitted: 6/27/2018 1:04:28 PM

Agree/Disagree: Disagree

Comment: 0140-1 Only Items that are developmentally appropriate and varied age ranges (see 0150-1-d). This is a duplication of some sections of 0150. The WAC should note the duplication so that there is not a resultant duplication of weight. This should not include items that are being stored and yet visible to the children.

Date Submitted: 6/27/2018 12:57:50 PM

Agree/Disagree: Disagree

Comment: 0130-2 Family Home programs should not be included in this mandate unless they have a child enrolled that requires these changes. FH programs are subject to WA residential building codes. 49.60.020 Nothing contained in this chapter shall be deemed to repeal any of the provisions of any other law of this state relating to discrimination because of race, color, creed, national origin, sex, marital status, sexual orientation, age, honorably discharged veteran or military status, or the presence of any sensory, mental, or physical disability, 49.60.215 PROVIDED, That this section shall not be construed to require structural changes, modifications, or additions to make any place accessible to a person with a disability except as otherwise required by law:

Date Submitted: 6/27/2018 12:39:32 PM

Agree/Disagree: Disagree

Comment: An early learning provider must have extra clothing available for children who wet, soil, or have a need to change clothes. What quantity of clothes by size, group, age or other criteria will satisfy this requirement and why isn't the rule that providers will require parents to provide a change of clothes for their children?

Date Submitted: 6/26/2018 3:26:25 PM

Agree/Disagree: Disagree

Comment: Early learning program space must allow children to move between areas without disrupting another child's work or play. What does this mean? What areas? What does disrupt mean? What would it look like? How much floor space would this require? How would DEL enforce this?

Date Submitted: 6/26/2018 3:12:29 PM

Agree/Disagree: Disagree

Comment: A CPR barrier is outdated. CPR is being taught now not using rescue breaths. Curriculum should be removed. Family childcare is not preschool.

Date Submitted: 6/26/2018 12:30:27 PM

Agree/Disagree: Disagree

Comment: Parents who choose to make their own diaper rash cream or sunscreen should be allowed to have us apply it with a signed permission slip. It's their choice not the dept. choice. A 24 inch area around a diaper changing area is not reasonable with Family childcare. We have limited space. Keeping pets out of the kitchen is not always possible with family childcare. Again it's our home. Also I'm not cleaning my pet's water dishes in the bathroom. With all the sanitizing we have to do in the kitchen, cleaning a pet dish shouldn't pose a health hazard. The outdoor play space should read outdoor play equipment when dealing with animal or bird waste. You can't disinfect back chips or grass.

Date Submitted: 6/26/2018 12:17:32 PM

Agree/Disagree: Disagree

Comment: As a family childcare provider, I use cloth towels to dry hands. We have a whole basket of them. The children dry their hands and place them in a can with a lid that I empty the can and wash them daily. I can't collect them after each use, I would be in the bathroom all the time. It is no more a hazard then having a garbage can for used paper towels and we only have to empty it daily.

Date Submitted: 6/26/2018 12:06:55 PM

Agree/Disagree: Disagree

Comment: If parents provide food for their children, We shouldn't add additional food without the parent's permission. It sends a message to the parent that they're not doing a good enough. Permission for food brought from home to be shared should be an annual one. Kids will bring things unannounced and want to share the treat they made with mom the night before. Family childcare provider's can't always sit with the kids while they eat. There are infants and toddlers to feed, seconds to get and cleaning up to do. When ever possible would be a better wording. Labeling everything in a family home provider's fridge is over reach. Again it is our home. We know when things were put in our fridge. A blanket 48 hours for left over food causes a lot of food waste. Many items are good up to 5 days.

Date Submitted: 6/26/2018 11:57:55 AM

Agree/Disagree: Disagree

Comment: The food program doesn't require a veggie or fruit at least one snack a day. Should only require what is required by food program. My daily menu is made every morning with the kids input. I don't want to take away their ability to help with daily menu planning. They are learning what makes up a balance meal and snack and they love getting to choose.

Date Submitted: 6/26/2018 11:44:12 AM

Agree/Disagree: Disagree

Comment: Safe noise level isn't always possible when children are playing. They can be loud and that can't be regulated. Better wording should be the adult voices and music be at a normal conversation level. I have GFCI outlets on all my outlets, they should be included as an alternative to covers. Filtered wading pools aren't easily acquired in my area. Emptied and sanitized daily should be good enough. Don't take the kids wading pools away. Tooth brushing requirement should be removed. Parent's can brush before coming and in the evening. We don't have the time to properly supervise children after each time they eat. Family childcare also doesn't have the space to store toothbrushes or a separate area for toothbrushing since the bathroom sink is for hand washing.

Date Submitted: 6/26/2018 10:38:03 AM

Agree/Disagree: Disagree

Comment: Family childcare is in our homes. We should not be required to ruin our walls, floors and furniture by securing large pieces of furniture and lamps. Since when is a lamp a hazard? Would you put screws or bolts in your hardwood floors, walls and tables to secure them? Temperature control should be reworded to try and keep at 82 or cooler. Some family providers don't have ac and can't afford it. Fans only cool a little. Why can't we open downstairs windows all the way? With a screen and required window height, it should be safe. We enjoy the air flow on nice days.

Date Submitted: 6/26/2018 10:28:29 AM

Agree/Disagree: Disagree

Comment: The requirement for all the materials and toys is not your job. Family childcare providers are small private businesses. We should be the judge on what should be in our home. Keeping toddlers away from screen time ids not always possible for Family childcare as we have limited space to do so. Tripping hazards are a part of life and sidewalks are not always trip free. Instead of requiring repair and replacement which can be cost prohibitive for Family childcare, we can teach children how to navigate these environmental hazards.

Date Submitted: 6/26/2018 10:21:59 AM

Agree/Disagree: Disagree

Comment: Many Family childcare providers do not have the space to do all the things you want put out for children to use. They need to put things out when they want to use them not have available all the time. Most homes do not have 2 exits from their outdoor space with one away from their house. Most homes have a house on each side and one behind. There is normally one gate and its beside the house.

Date Submitted: 6/26/2018 10:15:30 AM

Agree/Disagree: Disagree

Comment: WAC 0265 requires at least 18" between children while sleeping. And head to toe or toe to toe. The children are playing together all day and are closer than 18 inches. This is not a sensible rule. Some providers do not have enough floor space.

Date Submitted: 6/25/2018 10:39:30 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 4:53:18 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0185 Menus, milk, and food. 1 (a), (b) Reference to a menu is stated in 2 different ways...(a) "dated and (b) scheduled. Neither one of these terms clearly state that a rotating menu needs to be followed and it should include the date each meal and snack is to be served. The menu should reflect any changes that are made. To assure adequate balance and variety the rotating menu needs to be at least 2 weeks. The current week's menu needs to be posted. In addition to better assuring that children's nutritional needs are adequately met, a developed and dated menu provides the best record of the foods served at any meal or snack in child care. In case of a disease outbreak or illness, a menu provides data that could be critical to an investigation by public health officials. Thank you.

Date Submitted: 6/22/2018 11:34:41 AM

Agree/Disagree: Neutral

Comment: 0145(2) states "An early learning provider may develop an alternate plan if an early learning program does not have enough outdoor play space to accommodate all enrolled children at once..." Does this mean that more than two age groups can be on the playground at one time?

Date Submitted: 6/22/2018 8:00:50 AM

Agree/Disagree: Neutral

Comment: If they have the children's best interest at heart, meaning no additional costs to programs at centers or family day care homes.

Date Submitted: 6/21/2018 2:44:01 PM

Agree/Disagree: Disagree

Comment: Reading through and commenting on these proposed WAC's has taken an enormous amount of time. I am a home provider and so my opinion is from that standpoint. DEL has gone far and above the health and safety of the children of our state. DEL is attempting to make a law out of every move we make. DEL is requiring us to become educational institutions for every child we serve from birth on up. You are putting children in danger of a weakened immune system and by having such strict supervision and demanding interactions these children cannot possibly learn to function independently. All of the cleaning that you are requiring, curriculum and program agenda, community information to provide to parents, counseling to families and documentation of staff, children and program, continuing education beyond what is already required is absolutely impossible to meet all of these expectations. As a home provider I already wear many hats to operate my daycare successfully. I am not a sibling to Jesus thus I have no power to do miracles. What you are asking is beyond human ability. I challenge DEL to find anyone who can achieve every requirement you are attempting to place on us. You are leaving no room for us to actually be a home to the children we care for.

Date Submitted: 6/21/2018 10:30:57 AM

Agree/Disagree: Agree

Comment: 0345 -1 (d)A person authorized in writing or over the phone by that child's parent … This is great that a parent can call if need be to allow someone else to pick their child up.

Date Submitted: 6/21/2018 9:40:31 AM

Agree/Disagree: Agree

Comment: 0215 - Non medical items. Thank you for allowing us to annually authorize certain items such as sunscreen, diaper ointment, lip balm and lotion. Much improved over the 3 month rule. Obviously if a child is allergic we would suspend applying any of these items.

Date Submitted: 6/21/2018 9:25:57 AM

Agree/Disagree: Disagree

Comment: 0135 - (1) What are bucket style tables? Child size furniture. I have child size furniture and the children are always in the adult size furniture. This is an unreasonable requirement. 0140 - (4) Remove this item. It is not our responsibility to provide extra clothing for children. It is the requirement of the parent and although it is in my policy there are some parents who don't seem to get it. (5) I do have cubbies for my children but I know that in many homes this is just not possible giving the spacing needed between children's belongings. A large zip lock does not work because it is a plastic bag. Are you aware that children play together all day long and roll around on the same floor space?

Date Submitted: 6/20/2018 2:54:53 PM

Agree/Disagree: Disagree

Comment: Infant and Toddler Development, 0296 - 2 (b) i The following statement is insufficient to assure adequate floor time for babies: "Allowing each infant actively supervised tummy time through-out the day when the infant is awake." Please add an additional statement 0296 2 (b) ii Limit time that babies spend in infant equipment (containers) to two or fewer, 15 minutes sessions per day.

Date Submitted: 6/20/2018 11:43:08 AM

Agree/Disagree: Disagree

Comment: 170-300-0185, 1 (a) It is not enough to supply dated menus. In order for children to meet their nutrient needs they need balance and variety of foods offered consistently and intentionally. Please add the following statement: Must use a two week rotation menu and post a menu for the current week. (There are many resources available to child care providers for developing or finding already developed menus that meet the current CACFP meal pattern guidelines.)

Date Submitted: 6/20/2018 11:36:51 AM

Agree/Disagree: Agree

Comment: Medication: Need to add that rescue medications must be readily accessible. Recommended to be in Grab and Go Bags in each child's classroom, not down the hall in the office (which may be locked). And, you should address whether or not electronic documentation of medications is allowed by DEL. Many programs have all electronic documentation that are using for everything, including medication. Does the security of their system address HIPPA requirements for medication? Potty Training: Free-standing potty chairs are not mentioned here and are sometimes used in programs. Some parents have been asking providers to bring potty chairs with them on field trips. Not allowing should be specifically addressed. Diaper: For cloth diapers, the container from the family needs to be hands-free and impervious (just like the requirement for disposable). Diaper procedure: You need to specifically state "no standing a child on a diaper table." The risk of fall is too great. The statement: "never unattended" doesn't seem to cover "no standing" and I often see providers standing children up on the table to pull their pants up. Child Care Health Consultation: Great that you are keeping this one! Perhaps the Director of the program could be the one who reports to DEL. It would be great for them to put into words what they think the topic of conversation has been and in the process, see value added from that consultation. Bottle warming temperature: Need to state 120 F. Many, many bottle warmers are too hot! Safety requirements: Choking: no loop around the neck....this is great. You may need to specifically call out necklaces, particularly teething necklaces that either have choke-size beads or don't release when pulled on.

Date Submitted: 6/19/2018 10:13:59 AM

Agree/Disagree: Neutral

Comment: The proposed rules for include: 170-300-0165 Safety requirements. (5)(b) Outlets near sinks, tubs, toilets, or other water sources must be inaccessible to children or be tamper-resistant and equipped with a ground fault circuit interrupter (GFCI) outlet type; I wonder if the outlets around sinks, tubs, toilets, etc must be a GFCI outlet, or merely on a GGCI circuit that would trip the outlet and protect from shock. I don't believe code requires GFCI outlets in those locations, but it certainly requires GFCI protection for those outlets.

Date Submitted: 6/18/2018 8:41:02 AM

Agree/Disagree: Disagree

Comment: WAC 170-300-0180 (2) Tooth brushing after EVERY meal and snack? This is going to take a lot of time to implement in classrooms and is going to be a big power struggle for some kids. My concern here is that adults rarely brush their teeth after every meal and snack! Why are we making kids do that? I could see one meal a day, maybe lunch? But EVERY meal and snack seems very excessive (and is taking away from valuable play time that helps children learn and grow).

Date Submitted: 6/13/2018 10:45:38 AM

Agree/Disagree: Disagree

Comment: WAC 170-300-0140 5a I appreciate the fact that kids need their own personal space at their level, for kids 2 and up. I think infants and one-year-olds should be able to have their personal items up higher. Anyone who has worked in a classroom of infants and toddlers knows that having all their items down on their level, accessible to them, means that they will be tearing their stuff (and everyone else's) out all day. Please, if you could, make a change that allows infants and young toddlers to opt out of this rule.

Date Submitted: 6/13/2018 10:43:18 AM

Agree/Disagree: Disagree

Comment: P. 48 WAC 170-300-0140 Room arrangement, etc. 5. Request waiver – many of our spaces do not have individual cubby space for students. While we can create plans (ie: large ziplock backs for each student) for student belongings to be separated, we do not have the financial or space capacity to adjust cubby spaces at all locations. P. 52 WAC 170-300-0146 Equipment & surfaces in outdoor early learning Will be discussing with facilities department. Current playgrounds meet OSPI requirements/regulations P. 58 WAC 170-300-0160 Promoting acceptance of diversity 2. Will training be provided to support staff members in addressing these situations? P. 59 WAC 170-300-0165 Safety requirements • Will be discussing with facilities department. Current playground equipment & surfacing meets OSPI requirements/regulations. • 2b - Re: window blinds – all classrooms will need blinds replaced, which will be a financial constraint. Request waiver for alternate options to secure blind strings out of reach of children. • 4a – for classrooms located in school buildings, temperature control is not available in the classroom, but staff are able to call the custodian and request changes if outside of required range. • 4b – most, if not all windows in our programs open more than 3.5 inches. We will not have the capacity to replace all windows. Request permanent waiver. Windows do have screens in all windows. Also, some classrooms need window opening as a possibility to help regulate temperature (especially in portable classrooms, where the HVAC is challenged to keep up in extreme heat). Lastly, for emergency exit purposes, windows need to open more than 3.5 inches as for most classrooms they are the second exit. • 4c – will check with facilities on compliance of current light fixtures. May require significant replacement costs. • 4f.iii. – Not applicable to ECEAP at school locations because there are no infants/toddlers being served. Provide waiver for this requirement. P. 66 WAC 170-300-0166 Emergency preparation and exiting 2b. District has elaborate emergency operations plan and facility, but it is centrally located. Request waiver or variance to allow telephone requirement to be met by central phone as opposed to on site. P. 68 WAC 170-300-0170 Fire safety • Request waiver. Fire safety inspections are completed annually for schools per OSPI requirements. • 3g.ii – will need to check on requirements for carbon monoxide detectors. I’m guessing these are already required. P. 75 WAC 170-300-0180 Meal and snack schedule 1a – will the 2 hours between meal and snack be required? This will not work with our daily schedules when classes are only 2.75 to 3 hours. The amount of time required to get ready for meal/snack and then actual service creates barriers to separating these and still being able to meet other ECERS time requirements. P. 77 WAC 170-300-0185 Menus, milk and food 2. ECEAP requirements are just that a snack be offered. We have not previously had to have two components to the snack. Meals meet required component, but not snacks because they are not reimbursable. We pay for these out of our program budget and thus provide one item for snack option for students. P. 78 WAC 170-300-0186 Food allergies and special dietary needs Food allergy plans, modification and special dietary needs plans are completed in collaboration with school nurses. Add to language in this section to include collaboration with them (and/or ECEAP nurse) or provide variance that documents the collaboration as nurses will provide the training, etc. on what is needed to meet the student’s dietary needs. P. 81 WAC 170-300-0190 Parent or guardian provided food and written food plans 4. Will this apply to cultural foods preparation activities that occur in the classroom with a parent coming to cook with students? Will this apply to cultural food sharing activities in which parents bring/send a food that is a part of their family’s culture/traditional foods for children to taste and share? Can this permission be a blanket permission that is completed at the beginning of the year if so? P. 94 WAC 170-300-0205 Child, staff and household member illness 5f. School districts are not permitted to exclude children from school for lice (head lice). See OSPI Infectious Disease Control Guide. In addition, Snohomish Health District policy notes “No child should be kept home from K-12 school due to head lice.” As a district program, we follow the same guidelines that apply to K-12 as directed from OSPI. P.105 WAC 170-300-0220 Bathroom space and toilet training 1a. – request waiver. Our classroom spaces are dictated by space availability within the district and may change as needed. Classrooms vary from having bathrooms centrally located in the hallway to serve several classrooms, to having one bathroom in the portable classrooms. There is no way we can meet the requirement of 1 toilet for every 15 students and staff, nor do we have control over the size of toilets, depending on where we are placed. P. 116 WAC 170-300-0236 Safe drinking water 2a. Request waiver – our drinking fountains in the classrooms are attached to the one sink that is available in the classroom (classrooms with a bathroom in the room have an additional sink in the bathroom), thus this is a handwashing sink and the sink used for the drinking fountain. Faucets and drinking fountains are located on different sides of the sink, but share a sink. Without having these attached to this sink, they would not be available, in which case we would have to fill water jugs (from this sink) and have water and disposable cups available for students.

Date Submitted: 6/12/2018 12:00:45 PM

Agree/Disagree: Disagree

Comment: WAC 0285 requires we provide an area for mothers to breastfeed their children. Let them feed their babies in the privacy of their car, not in our home, where all the other children are oggled-eyed at what's going on. And we have to provide mothers with materials and resources to support breastfeeding? That's what their pediatrician is for. You are asking us to duplicate resources that easily attainable for any mother. One more thing to write us up for.

Date Submitted: 6/12/2018 11:20:15 AM

Agree/Disagree: Disagree

Comment: WAC 0280 Bottle preparation. Now we have to clean and sanitize the sink before adding water to a bottle that must be cleaned and sanitized in boiling water for one minute. Meanwhile the baby is screaming. This isn't realistic.

Date Submitted: 6/12/2018 11:17:46 AM

Agree/Disagree: Disagree

Comment: WAC 0265 requires at least 18" between children while sleeping. And head to toe or toe to toe. They spend all day closer than that. This serves no purpose other than something for DEL to measure (literally) when they visit. This is a waste of staff time. And in some family programs, there isn't enough room for this.

Date Submitted: 6/12/2018 11:15:34 AM

Agree/Disagree: Disagree

Comment: WAC 0255 requires us to document any evidence of pests. Why can't we just get rid of it? Why does this need to be documented. This is not enforceable unless DEL is on site when a pest is found.

Date Submitted: 6/12/2018 11:13:52 AM

Agree/Disagree: Disagree

Comment: WAC 0241 requires carpets be cleaned at least monthly if caring for infants. This will destroy the carpets in our homes. And add a substantial cost which will have to be passed on to the parents. We of course have the option of providing a "safe and clean material over large rugs or carpet" but what happens when the infant starts crawling. Now we need a safe and clean material everywhere. This serves no purpose. Please change this WAC.

Date Submitted: 6/12/2018 11:11:28 AM

Agree/Disagree: Disagree

Comment: WAC 0241 requires we clean and sanitize monthly our fridge and freezer. First of all, there are no living germs in the freezer because that's why its a freezer. Now, if DEL requires us to take all that food out, defrost, clean, and sanitize it monthly, where is all that food going to go while the work happens? This WAC will put the food at risk of thawing and becoming contaminated. This WAC does the opposite of what DEL probably intended. It needs to be deleted.

Date Submitted: 6/12/2018 11:08:59 AM

Agree/Disagree: Disagree

Comment: WAC 0241 - clean pacifiers after each use? By boiling or dishwasher? What is a "use"? A child spits it out and now we need a new one? Eventhough it's attached to their clothing and not falling on the floor? There aren't enough pacifiers for a day for this.

Date Submitted: 6/12/2018 11:06:32 AM

Agree/Disagree: Agree

Comment: WAC 0215 Medication permission. FINALLY, a WAC that makes more sense. This allows us to get annual permission for sun screen, diaper ointment, etc. instead of 3 months. Thanks.

Date Submitted: 6/12/2018 11:04:42 AM

Agree/Disagree: Disagree

Comment: WAC 0197 requires us to label food with the date opened or cooked before we put it in the fridge or freezer. We are home providers, not centers. Centers may have different cooks each week so they have to keep better track of when things were opened. Family providers are there every day - they know what's in the fridge. This is a ridiculous WAC for family providers. What about condiments? Do they have to be labeled also? Geez.

Date Submitted: 6/12/2018 11:02:37 AM

Agree/Disagree: Disagree

Comment: WAC 0196 Food sources. We can't buy food from the local farmer's market? Or roadside stands? And how will DEL know where the food came from? This is a WAC that is not enforceable, and just makes more tension between providers and DEL.

Date Submitted: 6/12/2018 10:59:58 AM

Agree/Disagree: Disagree

Comment: WAC 0180. Tooth brushing. Ridiculous. First off, who brushes their teeth 4X per day? And now you want us to do it for all the children in care? This is a huge time waster, and will cost staff time (think more payroll). We are not the parents. The parents can brush their teeth.

Date Submitted: 6/12/2018 10:54:08 AM

Agree/Disagree: Disagree

Comment: WAC 0146 (3) requires we must notify DEL prior to making handmade playground equipment and "have plans and materials list" available. What other business has to notify in advance if they are going to do something like this? This regulation is not necessary, and is nothing more than a way to find something to write us up on. A FLCA in the making.

Date Submitted: 6/12/2018 10:51:46 AM

Agree/Disagree: Disagree

Comment: Requiring toothbrushing after every meal is not acceptable.Children should brush their teeth twice a day, in the morning when they wake up and in the evening before bed. Requiring teachers to oversee toothbrushing is unrealistic.

Date Submitted: 6/12/2018 7:13:13 AM

Agree/Disagree: Disagree

Comment: It is totally nuts to want to have a classroom of 10-20 children brush their teeth after every meal or snack. It is hard enough and time consuming enough to get them to wash their hands 6-10 times a day. Jesus, you people need to get a grip with reality.

Date Submitted: 6/10/2018 1:16:58 PM

Agree/Disagree: Disagree

Comment: What if my neighbor doesn't want a gate into their back yard? Where am I supposed to have an exit? This will eliminate many family providers.

Date Submitted: 6/8/2018 3:00:36 PM

Agree/Disagree: Disagree

Comment: DISAGREE. child size furniture. Let's tell us what we can and cannot have in our daycare? Really. That is not what children in my daycare are used to. They want a down home feel atmosphere that is loving and caring. They don't care about the furniture,

Date Submitted: 6/8/2018 12:54:58 PM

Agree/Disagree: Disagree

Comment: We cannot be spending this ridiculous amount of time on toothbrushing! This is NOT what I should be getting paid for. It seems excessive. It is a parents responsibility. Many other problems with sanitation as well.

Date Submitted: 6/7/2018 8:43:26 PM

Agree/Disagree: Neutral

Comment: PROFESSIONAL DEVELOPMENT, TRAINING AND REQUIREMENTS How will the approved Department training be available? will this be provided on-line and will there be STARS credits associated to the training?

Date Submitted: 6/5/2018 2:43:47 PM

Agree/Disagree: Disagree

Comment: Family child care is family we typically in a family home do not have child size furniture. nor would I as a parent ask someone to brush my child's teeth during the day. Please do not change family child care into centers.. and even centers should not have to brush teeth.

Date Submitted: 6/4/2018 12:31:46 PM

Agree/Disagree: Disagree

Comment: While brushing teeth sounds like a good idea, there are a few considerations to examine. 1) The unreasonable amount of time it would require is a HUGE negative. 2) Since we have good dental care and fluoridated water in most places, it's not as critical as it used to be. 3) Having a sanitary and appropriate place do this can be quite difficult and probably expensive to provide. It's just a nice, but not very workable requirement.

Date Submitted: 5/26/2018 10:32:38 PM

Agree/Disagree: Neutral

Comment: WAC 170-300-0175 Water hazards and swimming pools. Washington State has a WAC for Swimming pools. The WAC is WAC 246-260-041 Portions of the Swimming Pool act require emergency, lifesaving equipment. I feel out WAC should have these items listed to the aligned WAC in regards to swimming pools on the premises whether they are in unlicensed space and not part of the program or are part of the program. In regards to Swimming pools on the premises but is inaccessible and not part of the childcare activities DEL could add a statement to the Declaration of Unlicensed Space form and have the provider declare emergency and lifesaving is available in case a child somehow enters unlicensed space and falls into the pool needing rescue. (11) Emergency equipment. Owners shall provide first aid and have emergency equipment readily available at swimming pool facilities during operating hours, including ii) A backboard with means to secure a victim to a board and immobilize head, neck, and back. (g) For pool facilities without lifeguards: (i) A reaching pole at least twelve feet long with a double crook life hook; (ii) A reaching pole at least twelve feet long for every fifteen hundred square feet of pool surface area; and (iii) A throwing buoy, throw-rope bag, or other similar device with a rope the width of the pool or fifty feet long, whichever is less, for reaching and retrieving a victim

Date Submitted: 5/25/2018 8:48:22 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0260 Storage of hazardous and maintenance supplies. (1) An early learning provider must ensure all poisonous or dangerous substances including, but not limited to, fuels, solvents, oils, laundry, dishwasher, other detergents, sanitizing products, disinfectants and items labeled "keep out of reach of children" are stored: (a) In a location that is inaccessible to children; Please provide a clearer definition of what type of location would be appropriate. 5 ft. or higher in a shelf? if lower in a locked shelf? There has been much inconsistency in regulating this WAC. Give licensors and early child care providers a concrete definition so regulating can be consistent.

Date Submitted: 5/25/2018 6:47:15 AM

Agree/Disagree: Disagree

Comment: Please do not force child care providers to brush teeth during the day. This is the responsibility of the parents to teach their children and to have their children do so twice daily. It's ridiculous to try to have teachers spend time having every single child brush their teeth multiple times per day.

Date Submitted: 5/24/2018 4:36:26 PM

Agree/Disagree: Disagree

Comment: While I agree with some of these changes, I see that I am not alone in my opposition of requiring toothbrushing after each meal and snack. I struggle to even find the words to express how insane this is. Children should brush their teeth twice a day, in the morning when they wake up and in the evening before bed. To be effective, brushing must last for at least two minutes. Requiring teachers to oversee toothbrushing of 18 children and ensuring tht at it is effective is unrealistic at best. This take away more time from the children's play and learning. Ridiculous.

Date Submitted: 5/24/2018 2:38:14 PM

Agree/Disagree: Disagree

Comment: Whoever is coming up with these new rules need to remember that we're a FAMILY childcare. The families that bring their children to us is because they like the family environment. We're not a center. Every time there's a change family childcares are forced to close their doors. Then all we hear is how there isn't enough childcare. I wonder why that is? Just ridiculous.

Date Submitted: 5/23/2018 2:59:00 PM

Agree/Disagree: Disagree

Comment: It is the job of the parent to brush their child's teeth before drop off and after pick up. It should not fall on the provider- what's next? Clipping their nails? Scheduling doctor's aapointments?

Date Submitted: 5/23/2018 12:59:48 PM

Agree/Disagree: Neutral

Comment: 170-300-0215 (3)(e) If under section 170-300-0215 (3)(a)(iii) “homeopathic or naturopathic medication” can be administered under the parent and medical permission, which should include the use of essential oils, shouldn’t the parent and medical personnel be able to give permission to use homemade diaper cream or sunscreen which is commonly made from homeopathic or naturopathic methods?

Date Submitted: 5/20/2018 1:17:28 PM

Agree/Disagree: Neutral

Comment: 170-300-0197 (7)(a) “Leftover food” needs to be defined. This needs to be more specific to each type of food. A leftover meat product will spoil quickly more quickly than other types of foods. However, leftover fruit or cheese for example will last longer. Does this mean that if a gallon of milk is opened and now “leftover” that it must be used within 48 hours? What about condiments like butter and ketchup? Non-refrigerated food should also be defined for how long each type of food can be kept, for instance crackers, rice, syrup, etc. These are things that have a “best by” date, but once opened needs a defined amount of time to follow in order to discard when necessary.

Date Submitted: 5/20/2018 1:17:01 PM

Agree/Disagree: Neutral

Comment: 170-300-0185 (1) Following the “USDA Child and Adult Care Food Program (CACFP Handbook” does not accurately comply with current CACFP standards. The current handbook for licensed centers was last updated in 2014. However, major changes took effect in October 2017. Therefore, this section should state “…must comply with the requirements as mandated by CACFP”.

Date Submitted: 5/20/2018 1:16:37 PM

Agree/Disagree: Disagree

Comment: 170-300-0180 (2) This section needs to be more realistic for center-based care. In a room of 14 1 or 2-year-old children or a room of 20 3 or 4-year-old children, brushing after each meal and snack, often only two hours apart, is unrealistic. The section could read “after at least one meal, such as breakfast, lunch or dinner”. It is common knowledge that children should brush twice per day. It is unrealistic for providers to offer opportunities for children to brush their teeth after each meal and snack, which would be four times per day while in licensed care- not to mention the additional brushing children should be doing at home before and after being in licensed care.

Date Submitted: 5/20/2018 1:16:14 PM

Agree/Disagree: Disagree

Comment: 170-300-0145 (11) This section needs clarification. This is stating that “gates from a licensed outdoor play area to unlicensed space” can’t have locks on the gates? If a fence requirement is 48”, even an older child could open the gate. This is a safety concern as many licensed outdoor spaces are near parking lots or roads. Additionally, if these gates can’t have locks, the licensed outdoor space will not prevent people from outside the outdoor play space from entering, again threatening the safety of the staff and children. The section should allow for locks on all gates, as long as a key readily accessible in case of emergency.

Date Submitted: 5/20/2018 1:15:31 PM

Agree/Disagree: Disagree

Comment: 170-300-0140 (5)(a) To maintain children’s belongings in an individual manner, cubbies should not be required to be accessible for children under two years old. The age of the child is not specific here. Infants especially should not have access to individual storage spaces. Once children increase in independence and understanding that they should leave cubbies alone so that all children’s belongings remain in their cubbies, then they should be permitted to have cubbies accessible. Preferably, this should read “accessible to the child either by direct access or with an adult’s assistance” instead of requiring access to “the child”. Without this flexibility in access, 170-300-0140 (5)(b)(ii) rooms with young children will have an incredibly difficult time meeting this requirement.

Date Submitted: 5/20/2018 1:14:45 PM

Agree/Disagree: Disagree

Comment: (4) An early learning provider must have extra clothing available for children who wet, soil, or have a need to change clothes. Question: When did we become a society of taking the responsibility away from the parents? We keep extra clothes on site but I will always hold the parents responsible first. The clothes we provide are for emergencies only.

Date Submitted: 5/18/2018 4:14:25 PM

Agree/Disagree: Disagree

Comment: I don't feel it's up to us to be required to brush teeth. This is the parent's responsibility. I don't think it's appropriate for us to follow ADA guidelines, as an in home provider my home is private. I am not open for business to the entire public to drop in anytime during business hours.

Date Submitted: 5/18/2018 9:51:24 AM

Agree/Disagree: Disagree

Comment: 0221 Diaper changing and tooth brushing. (1) A diaper changing area must: (i) Be separate from where food is stored,prepared or served (ii) Have a sink with hot and cold running water,not used for food preparation and clean up. WHY if it's sanitary enough for 10 children 4X a day to brush their teeth it must be sanitary enough for food prep and serving and food prep right? tooth brush, toothpaste and water from the diaper changing hand washing goes into their mouth and most likely swallowed.

Date Submitted: 5/17/2018 10:56:25 PM

Agree/Disagree: Disagree

Comment: 0220 (B)(vi) Bathroom sinks must not be used as a drinking water source or for food preparation why is that sink allowed for tooth brushing. This makes no sense?????

Date Submitted: 5/17/2018 10:46:02 PM

Agree/Disagree: Disagree

Comment: 0180 Toothbrushing two meals two snacks. 4 times a day a caretaker has to help ten children brush their teeth in a safe sanitary manner ? What sink will they use the bathroom or the kitchen? When will learning activities occur. There will be unsanitary situations. chaos, lack of supervision and no learning occurring 4 x a day. These children are in early learning programs not an orphanage. Teeth brushing is a parent/guardian responsibility and should be done in the child's home.

Date Submitted: 5/17/2018 10:33:41 PM

Agree/Disagree: Disagree

Comment: 170-300-0180 (2) Toothbrushing- There is no way toothbrushing can be sanitary. Water from a hand washing sink where the tooth brushing would take place should not be put into the mouth. If the water from a hand washing sink cannot be used for drinking water why would you use that water to brush teeth and rinse. Child care bathrooms are just like public bathrooms and have fecal matter floating in the air. It would get on the toothbrushes and paste when applied etc. Allow the provider to opt out and inform parents in the parent policy. E Coli can be spread airborne. Exposing the toothbrush applying toothpaste and then using sink water is not Safe! Yech ! Yech!. Supervision of the child tooth brushing and then supervising the other children is not possible DEL puts it at great risk of being sued if they require tooth brushing and it causes illness or an injury due to supervision issues. I would never brush my teeth in a public bathroom why are you requiring children to??

Date Submitted: 5/17/2018 10:02:05 PM

Agree/Disagree: Disagree

Comment: 170-300-0146 (b)(ii) please be more descriptive on the type of Playground wood chips childcare providers may be required to purchase expensive products who cannot guarantee no slivers. The CPSC public playground guidelines states:2.4 Appropriate Surfacing • Any material tested to ASTM F1292, including unitary surfaces, engineered wood fiber, etc. • Pea gravel • Sand • Shredded/recycled rubber mulch • Wood mulch (not CCA-treated) • Wood chips This is three types of wood product as acceptable wood ground cover. Caring For Our Children and the EA rating scale also accepts three types of wood product. Please be clear on the three types for providers will not be required to purchase expensive products marketed as playground chips when wood chips, mulch and unitary surfaces, engineered wood fiber are all considered appropriate wood groundcovers.

Date Submitted: 5/17/2018 8:53:06 PM

Agree/Disagree: Disagree

Comment: 170-300-0145 (8)(9) building code of gaps are 4 inch gaps it would be unfair to have providers alter their fences that were built to the building code.

Date Submitted: 5/17/2018 8:05:35 PM

Agree/Disagree: Disagree

Comment: 0180- I do not think providers should be required to brush kids teeth. This should be a parents responsibility. When would we have time to do this with all of the other requirements and new regulations?! You are asking us to take on more and more of parent responsibilities. We are basically sending kids home to sleep and doing everything else while they are in our care. Absolutely ridiculous.

Date Submitted: 5/17/2018 12:52:50 PM

Agree/Disagree: Neutral

Comment: I should not have to comply with the ADA as concerns Family Home Daycare. We are a family environment, not a business like a center.

Date Submitted: 5/16/2018 2:02:20 PM

Agree/Disagree: Neutral

Comment: I should not have to comply with the ADA as concerns Family Home Daycare. We are a family environment, not a business like a center.

Date Submitted: 5/16/2018 2:02:12 PM

Agree/Disagree: Neutral

Comment: You are defining the differences between early learning providers. Many of these rules do not apply to my childcare which is only before and after school care. Such as furniture for their size. WE are family home childcare businesses. People choose us because they want a "family" environment, not a "center" environment. I may end up quitting if this changes significantly.

Date Submitted: 5/16/2018 1:56:12 PM

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