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

New Licensing Rules
Definitions that accompany aligned licensing rules that will replace current center and family home child care rules, chapters 170-295 and 170-296A.

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: Center and Home Providers are very different and I think it impossible and a waste of time and money to try and align them.

Date Submitted: 6/27/2018 10:26:06 PM

Agree/Disagree: Disagree

Comment: In regards to WAC 170-300 Definition of a Toddler I disagree with changing the age definition of a toddler. It should remain at 16-36 months of age as stated in The Early Learning and Development Guidlines by Department of Early Learning, page 41. Head Start, EACAP and Birth to Three programs all agree that Preschool starts at age 3 years. Thank you for your careful consideration. Laura F- Lead Teacher 3 year old class of an Early Achievers Center

Date Submitted: 6/27/2018 9:39:13 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 9:34:47 PM

Agree/Disagree: Disagree

Comment: 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. The new aligned WAC’s 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 8:55:45 PM

Agree/Disagree: Disagree

Comment: "Foundational quality standards" is a fancy change from minimum licensing requirements. I believe the Department (DEL) has severely over reached in its revamp of the WACs. “DEL” has become the biggest threat to the childcare industry in the state of Washington. What ever happened to serving the people of the State of Washington? Providers are the people. In the five years I have been a child care provider, DEL appears to have moved to a mindset of protecting the bureaucracy at the expense of children. "Preschool-age children" Should mean children thirty-six months through six years of age not attending kindergarten or elementary school. This would be consistent with national standards and the needs of young children. "Toddler" Should mean a child twelve months through Thirty-five months of age. This would bring Washington in line with national standards. For the last two years my program has had a two year old class room for kids 24-35 months. It protects the younger toddlers (under 24 months) from the more aggressive older toddlers. It also allows the 30-35 month old kids to master potty training and further develop other social skills and self-care skills before moving to a larger group and higher child to teacher ratio.

Date Submitted: 6/27/2018 2:25:00 PM

Agree/Disagree: Disagree

Comment: This is regarding new WAC 170-300. Children considered toddler age should be up to the age of 36 months. Children at 2 and a half years of age shouldn't be placed in a preschool classroom just yet. This 6-month age gap makes a huge difference developmentally for children. Also, having toddler age up to 36 months will also meet national standards, product safety labels and the programs within DEL that consider infants and toddlers to be children under 3 such as ESIT, Home Visiting, the Early Learning and Development Guidelines, and the EHS Childcare Partnerships. Thank you, Monica Rodriguez Family, Friend and Neighbor Program Coordinator 10-year employee Catholic Charities Serving Central Washington - Child Care Aware program

Date Submitted: 6/27/2018 1:57:21 PM

Agree/Disagree: Disagree

Comment: 170-300 WAC/ Definition of Toddler. Monica Althaus- DEL Infant Toddler Consultation/CCDF funded/ I have been a Consultant/Coach for over a year with Catholic Charities, and previously a Preschool, infant and toddler teacher for over 16 years. The following is the definition you have listed for Toddler: ""Toddler" means a child twelve months through twenty-nine months of age." I do not agree with this definition for many reasons, a Toddler should be considered 12 months to 3 years of age (12 to 36 months). Children under the age of three still need more Teacher guidance and help. For child care providers, this can also cause a burden when choosing materials for their preschool classrooms when there are many materials that are clearly labeled “not for children under 3 years of age”. Changing the definition to 36 months will align this WAC with National standards, product safety labels and many DEL programs. I believe the first three years of life is crucial, there should be more Funding going to infant and toddler programs, and more support from the state and government to produce quality care for those crucial early years. I believe changing the definition will also relieve some stress put on the providers and give children more flexibility and time to grow...as well as help to send more potty trained children to preschool classroom. Please consider my comment, and please let me know if you want to talk further with me on this topic. Thank you for your consideration.

Date Submitted: 6/27/2018 1:19:14 PM

Agree/Disagree: Neutral

Comment: We believe childcare centers should be allowed the flexibility to meet the unique needs of the children and parents they serve, their communities, and their employees. We remain concerned that throughout this standardization process the ability to be flexible and innovative with program delivery and quality is significantly impaired. The needs of parents and employers are unique, the application of a one size fits all standard does a disservice to all and will place additional limits on the accessibility and affordability of childcare. We also ask that their be a careful and thoughtful review of the weighting for each item. There exists the potential for duplication of weights and unnecessarily high weighting on infractions that are beyond the control of the center.

Date Submitted: 6/27/2018 12:23:28 PM

Agree/Disagree: Disagree

Comment: WAC 170-300 Definitions. I represent DEL Infant Toddler Consultation/CCDF funded as an Infant Toddler Coach. I have been in this role for nearly 3 years and am in infant and toddler classrooms supporting those teachers almost daily at a number of child care programs in our community. The idea that a "Toddler" would be defined as 12-29 months does not align with many other programs, and to expect a 2 1/2 year old to be in a classroom with other children 3 years and up is not developmentally appropriate. The definition of "Toddler" needs to change to 12-36 months. As it currently is, these teachers in preschool classrooms with 2 1/2 year olds does not set teachers or children up for success. Please change definition of toddler to 12-36 months to better support the children in our communities, and the hard-working teachers that support them.

Date Submitted: 6/27/2018 11:30:26 AM

Agree/Disagree: Disagree

Comment: “Discipline” is not redirection. This is only a component for very young children. Preschool and school age children will not respond to redirection. The root meaning of discipline is “teach” and “lead.” (Constructive Guidance and Discipline, 2018) Consequences for inappropriate behavior need to be based on DAP and the individual child, not punishment. Discipline needs to lead to self-regulation, which redirection does not accomplish. “Inaccessible” definition is impossible to comply with due to the varied ages and developmental levels in a Family Home program. Some school age children are more than capable to unlock or access something if so inclined. Our homes would have to be a fortress with keys on our persons at all times. Supervision needs to be a part of inaccessible. Knowing the children in care and their individual abilities is a better way of judging the process needed to make areas or items inaccessible. The official definition of inaccessible is “difficult or impossible to reach, approach, or understand: not accessible. Hard or impossible to reach or get hold of.” (According to the Merriam Webster dictionary) The definition should return to: "Inaccessible to children" means an effective method or barrier that reasonably prevents a child's ability to reach, enter, or use items or areas. WAC 170-296A-0010 “Family living quarters” should not include “other spaces or building on the premises.” In a Family Home program this is an invasion of privacy. Children in care do not have access to these areas so it should not be included in the definition. There is nothing in the RCW that includes outbuildings and premises. RCW 43.216.010 (c) "Family day care provider" means a child care provider who regularly provides early childhood education and early learning services for not more than twelve children in the provider's home in the family living quarters;

Date Submitted: 6/27/2018 10:20:57 AM

Agree/Disagree: Agree

Comment: 170-300-0291 Infant safe sleep practices. Please file an Emergency Rule and replace the current inappropriate Safe Sleep WAC with the proposed one. DEL needs to stop stop citing providers for toddler age children in regards to Safe Sleep violations immediately.!!!!!!!

Date Submitted: 6/26/2018 10:17:05 PM

Agree/Disagree: Disagree

Comment: 170-300-0016 Inactive status – voluntary and temporary closure. 1) If a center or family home licensee plans to temporarily close their early learning program for more than 14 calendar days, and this closure is a departure from the program’s regular schedule, an early learning provider must submit a request to go on inactive status to the department at least two business days prior to the planned closure. Requests for inactive status must include: (a) The date the early learning program will cease operating; (b) A reason why the licensee is requesting an inactive status; and (c) A projected date the early learning program will reopen. Weight #1 Taking some time off from work does not imply we are closing our childcare! Having to go into an inactive status is wrong. We are not closing, only taking some time off. 14 days! That's a normal vacation time. I could see if it was a 3 month period of time, but this is outrageous.

Date Submitted: 6/26/2018 9:03:15 PM

Agree/Disagree: Disagree

Comment: I am a in home child care provider. I offer a home atmosphere that is safe and loving, teaching manners, respect, kindness, empathy and learning through play. This is why I was chosen by clients. In home providers should not be forced to be called “Early Learning Providers”

Date Submitted: 6/26/2018 1:35:28 PM

Agree/Disagree: Disagree

Comment: Why are children above preschool age not included in this definition and toddlers are capable of playing together and preschoolers may play near one another without playing together. "Peer interaction" refers to relationships children have with one another, which includes how infants and toddlers play near one another and how preschoolers play together, communicate, and whether they fight or get along.

Date Submitted: 6/25/2018 5:06:05 PM

Agree/Disagree: Disagree

Comment: What if you have a house or building with lots of natural light and a large view or the rooms with few or no windows are too small to place all the children in? What if the room is outside of licensed space? "Lockdown" means restricted to an interior room with few or no windows while the facility or building is secured from a threat.

Date Submitted: 6/25/2018 5:00:47 PM

Agree/Disagree: Disagree

Comment: Does creating a formal plan undermine "at will" employment status in the State of Washington? This kind of plan implies increases in compensation. Who will provide the money to pay staff well when families are paying 20% of their income to child care as it is now? "Professional development support plan" is a formal means by which an individual who is supervising staff sets out the goals, strategies, and outcomes of learning and training.

Date Submitted: 6/25/2018 4:35:05 PM

Agree/Disagree: Disagree

Comment: Either use "variance" or "waiver" as the term and avoid confusion by the use and definition of both for a similar purpose. "Variance" is an official approval by the department to allow an early learning program to achieve the outcome of a rule or rules in this chapter in an alternative way than described due to the needs of a unique or specific program approach or methodology. The department must grant a request for variance if the proposed alternative provides clear and convincing evidence that the health, welfare, and safety of all enrolled children is not jeopardized. An early learning provider does not have the right to appeal the department's disapproval of request for variance under chapter 170-03 WAC, as hereafter recodified or amended. The provider may challenge a variance disapproval on a department form. "Waiver" is an official approval by the department allowing an early learning provider not to meet or satisfy a rule in this chapter due to specific needs of the program or an enrolled child. The department must grant a request for waiver if the proposed waiver provides clear and convincing evidence that the health, welfare, and safety of all enrolled children is not jeopardized. An early learning provider does not have the right to appeal the department's disapproval of a waiver request under chapter 170-03 WAC, as hereafter recodified or amended.

Date Submitted: 6/25/2018 4:27:28 PM

Agree/Disagree: Disagree

Comment: Who will be paying for these quality standards if all the parents are privately paying for care? What if families cannot afford the increased cost of these standards? Where have all the children who were in licensed care gone since so many homes and centers have closed? How does creating standards help children if it has driven parents into unlicensed or unpredictable care situations? DEL is regulating an entire industry out of business while not ensuring children are cared for while parents work. "Foundational quality standards" refers to the administrative and regulatory requirements contained within this chapter. These standards are designed to promote the development, health, and safety of children enrolled in center and family home early learning programs. The department uses these standards to equitably serve children, families, and early learning providers throughout Washington state.

Date Submitted: 6/25/2018 4:20:12 PM

Agree/Disagree: Disagree

Comment: Why is this changed from "child care" to expand the meaning into education. What about someone who only takes infants? How is that a program? Why do you need a program to provide loving, home like care to small children? "Family home early learning program" means an early learning program licensed by the department where a family home licensee provides child care or education services for twelve or fewer children in the family living quarters where the licensee resides as provided in RCW 43.216.010 (1)(c) (family day care provider).

Date Submitted: 6/25/2018 4:13:38 PM

Agree/Disagree: Disagree

Comment: There are other reasons to end an enrollment beyond being unable to meet a child's needs. What if there is no room in the next age group as a child ages? "Expel" or "expulsion" means to end a child's enrollment in an early learning program. An early learning provider will end a child's enrollment if the provider is unable to meet a child's needs due to the child's challenging behavior.

Date Submitted: 6/25/2018 4:07:16 PM

Agree/Disagree: Disagree

Comment: I object to the use of "is allowed" rather than "does meet" the requirements. "Equivalency" when referring to staff qualifications means an individual is allowed to meet the requirements of this chapter through a department recognized alternative credential, or demonstration of competency, that indicates similar knowledge as the named credential

Date Submitted: 6/25/2018 4:02:31 PM

Agree/Disagree: Disagree

Comment: Early achievers is a quality improvement and rating system. This definition overstates what Early Achievers provides. "Early achievers" is a statewide system of high-quality early learning that connects families to early learning programs with the help of an easy to understand rating system and offers coaching, professional development, and resources for early learning providers to support each child's learning and development.

Date Submitted: 6/25/2018 3:57:14 PM

Agree/Disagree: Disagree

Comment: Discipline includes more options than just redirect. "Discipline" means a method used to redirect a child in order to achieve a desired behavior.

Date Submitted: 6/25/2018 3:52:23 PM

Agree/Disagree: Disagree

Comment: Eliminate the specific bleach to water ratio which does not take into consideration that bleach is available in differing concentrations. "Disinfect" means to eliminate virtually all germs from an inanimate surface by the process of cleaning and rinsing, followed by: (a) A chlorine bleach and water solution of one tablespoon of chlorine bleach to one quart of cool water, allowed to stand wet for at least two minutes; or (b) Other disinfectant products registered with the EPA, if used strictly according to the manufacturer's label instructions including, but not limited to, quantity, time the product must be left in place, adequate time to allow the product to dry or rinsing if applicable, and appropriateness for use on the surface to be disinfected. Any disinfectant used on food contact surfaces or toys must be labeled "safe for food contact surfaces."

Date Submitted: 6/25/2018 3:46:58 PM

Agree/Disagree: Disagree

Comment: As a licensed family childcare provider, my clients choose my home childcare to provide licensed, caring, nurturing, safe and loving home environment childcare for their children. I'm not an early learning provider. I don't feel Early Learning should be regulated in our WACs. It is a choice for each family childcare to offer what they want in their setting. They are private business owners not employees of DEL or "DCYF". They are owned primarily by women. Parent's have the responsibility to choose what they feel is important for their children and you are taking that choice away from them. Everything that has to do with early learning, curriculum, and lesson planning should be removed from these WACs. You have over stepped your bounds of health and safety.

Date Submitted: 6/24/2018 3:55:34 PM

Agree/Disagree: Neutral

Comment: I would hope that changes in definitions would have the children's best interest at heart meaning the change in the definitions would not add additional costs monthly or yearly costs to centers or family day care homes.

Date Submitted: 6/21/2018 2:41:09 PM

Agree/Disagree: Disagree

Comment: Early Learning Provider - I am an in-home child care provider that cares for children. Ensuring their health and safety to the best of my ability while their parents are working. I do a preschool program by choice. We each learn new things every day just as any typically functioning human being does. I do not want to be referred to as an "Early Learning Provider" as if my job is to drill learning into the children that I care for at every waking moment from the time they enter my day care at 3 months of age until they no longer attend. Are we exterminating people who love to be with kids and help them to learn manners, the golden rule, make sure they are fed and safe in an effort to set them on a path of being a genius? There are 8 definitions in this document that begin with "Early". Give it a rest and let these children learn at their own pace. In my opinion our job is to provide opportunity and encouragement not implement the states agenda.

Date Submitted: 6/20/2018 8:45:53 AM

Agree/Disagree: Neutral

Comment: What are the rules

Date Submitted: 6/19/2018 5:11:44 PM

Agree/Disagree: Disagree

Comment: A home setting is very different than a childcare center setting which is also different than an ECEAP setting. They should not be required to follow the same rules. A home setting is meant to be more comfortable and relaxed. The parents putting their children here a looking for specific things not offered by the other two settings. A Center also has specific things to offer that are not offered by the others. Making everyone follow the same WACS takes away what gives each setting its uniqueness.

Date Submitted: 6/19/2018 11:02:36 AM

Agree/Disagree: Disagree

Comment: What are higher risk activities this WAC anticipates? What does instantly mean when it is a group of children not one? "Active supervision" or "actively supervise" means a heightened standard of care beyond supervision. This standard requires an early learning provider to see and hear the children they are responsible for during higher risk activities. The provider must be able to prevent or instantly respond to unsafe or harmful events.

Date Submitted: 6/19/2018 10:44:28 AM

Agree/Disagree: Agree

Comment: I would suggest a definition of "reside" relevant to a licensed family home provider. There are currently no guidelines for those instances in which we are aware that a family home provider owns and resides in two homes.

Date Submitted: 6/15/2018 2:17:45 PM

Agree/Disagree: Disagree

Comment: We have had a staffing problem the entire school year. The number of qualified applicants continues to DECREASE even or in spite of the current program to pay for people's training. I would love a qualified substitute list to choose from; I need a new hire start as soon as hired NOT WAITING for the background check. I agree with a preliminary or probationary period they can work while the background is adequately verified

Date Submitted: 6/8/2018 1:24:28 PM

Agree/Disagree: Disagree

Comment: DISAGREE.....THEY ARE ALREADY HAVING ISSUES WITH THEIR DEFINITIONS. THEY ARE UP TO INTERPRETATION OF THE LICENSOR AND THE SUPERVISORS. THEY ARE NOT EVEN FOLLOWING THE DEFINITIONS AS WROTE CURRENTLY, HOW CAN THEY POSSIBLY DO IT TO THE NEW RULES AND DEFINITIONS. GET REAL PEOPLE.

Date Submitted: 6/8/2018 12:52:38 PM

Agree/Disagree: Disagree

Comment: We should be allowed to use our small wading pools in our home childcare! Ours are refilled several times a day and are used for SO many fun activities. Please allow them!

Date Submitted: 6/7/2018 8:21:18 PM

Agree/Disagree: Disagree

Comment: RE:(3) Filtered wading pools must be inaccessible to children when not in use. Wading pools that do not have a filtering system are not permitted in the early learning program space. This ruling should be changed to allow for small wading pools that are changed and cleaned daily. If we can not use affordable wading pools, we will be wasting valuable water resources for the community by running sprinklers all day in the sun. The children in my care are all school age, and I can not see the need for a filter (and frankly have never seen a wading pool with a filter). I own 3 Little Tykes type pools and we clean the pools and change the water daily. May I also comment on the use of hand-sanitizes in child care. I am perplexed as to why Early Achiever facilities use hand sanitizes on children several times per day and home daycare's are not allowed to unless there is no running water available. I completely understand washing after using the bathroom and prior to eating, but I also like my kids to clean their hands upon entering daycare as well as coming back from school. I am curious as to why the rules are different for both State-run programs. Thank-you.

Date Submitted: 6/4/2018 8:37:44 PM

Agree/Disagree: Neutral

Comment: I am asking for a clarification on this definition. Will magnetic locks still be allowed as they currently are? "Locking mechanism" means a lock that requires a key, tumbler, dial, passcode, touchpad, or similar device or method to lock and unlock.

Date Submitted: 5/29/2018 9:12:50 PM

Agree/Disagree: Disagree

Comment: I think teacher to child ratios need to be dropped to be able to implement the new rules and expectations

Date Submitted: 5/24/2018 1:36:46 PM

Agree/Disagree: Neutral

Comment: "Inaccessible to children" means a method to prevent a child from reaching, entering, using, or getting to items, areas, or materials of an early learning program. Please give some definite examples to how to make unlicensed space inaccessible. Some licensors, offices, allow Door Knob covers on doorways that lead to un licensed space. Others do not. If it's a product sold as a child proof item should we accept it, if it's approved by the CPSC? There is also much inconsistency in regards to outlet covers Some outlet covers have additional child proof steps causing them to be almost impossible for even an adult to remove. DEL need to be consistent about the type of child proof items we can use. So licensors and providers can have a clear understanding what is acceptable in making unlicensed space inaccessible.

Date Submitted: 5/23/2018 10:08:24 PM

Agree/Disagree: Disagree

Comment: Please give measurable criteria in regards to the definition terms "Accessible and Inaccessible" "Accessible to children" means items, areas or materials of an early learning program that a child can reasonably reach, enter, use, or get to on their own. "Inaccessible to children" means a method to prevent a child from reaching, entering, using, or getting to items, areas, or materials of an early learning program. There is inconsistency in regards to how licensors make the decision in regards to household cleaners, hand soap, shampoo, dish soap also. A child cannot easily reach the dish soap back on the counter as far as it can be away from the edge. Is it were a toy it would be cited as not accessible but is cited accessible when it comes the dish soap. Some licensors cite for toxins being accessible if items are on high shelves because a child "could" climb a chair then climbing onto the kitchen counter and then reaching a soap etc. that is 9ft off the floor. Can licensors be consistent. Can providers have a clear definition measurable so they can avoid being cited if a different licensor inspects the facility.

Date Submitted: 5/23/2018 9:56:21 PM

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