Page 43 Line 1222 & Page 45 line 1276

Is not a director or master teacher at another program that operates concurrently at any given time

As a director of a 24 hour facility I don't think this proposed regulation takes our industry into account. If an individual is employed at one place from 6 to 2 and works for me from 3 -11 they should be counted as a Master Teacher. I believe the wording should be changed to reflect the intent ... possibly "not at the same time"

Page 44 Line 1254
Personnel in charge. Appointed personnel meet the personnel in charge qualifications and responsibilities. Need to reference line 1225 and underline 1255. Take out qualifications and leave responsibilities for staff in charge. As it reads it would require staff in charge to have a director’s credential. Removing the word qualifications would alleviate the need for a director’s credential for a staff in charge.

Page 89 line 2456 & 2466 regarding fat content and chocolate milk
CACFP has federal guidelines. I feel we should make sure our state requirement is aligned with the federal requirement in this instance. Many of our child care programs receive funding from CACFP. Their research shows children need the milk no matter how they get it.

Mixed-Age Group Chart
1 year olds and older – includes a 3 year old or older

Only age group that you must have an older child to bring in younger children. This regulation is not conducive to transitioning up the toddlers to the two year old classroom. This is the only age group that requires an older child to be placed in the mixed group ratio.

I appreciate DHS is trying to clean up the language to make it less confusing but let's get rid of it all together and allow 2 toddlers with 6 two year olds and maintain the 2 year old ratio.

Page 107 Line 3111

Playground equipment that is 30 inches or less, extend at least three feet in all directions from the equipment perimeter, unless an exception in (b) of this subsection applies


In current standards anything over four feet requires impact material. Why the drastic jump?

Page 16 line 521
Tornado drills performed monthly. This seems excessive. We aren't in tornado season every month.

Page 16 line 523
Lock-down review performed every three months. This seems excessive. What is occurring every three months that mandates a review.

Page 17 line 540:
known legal action, such as a victim protective order, arrest, or criminal investigation or charge, involving the program, owner, responsible entity, personnel, or an individual living in the facility
Please define legal action involving personnel, i.e. a wife against a husband. So if I have an employee that has filed a VPO against her husband I have to call and report that?

Page 17 line 548:
an incident that exposes the children to an imminent risk of harm, such as a child leaving the facility without the program’s knowledge or being left alone on- or off-site in a vehicle.
No harm no foul. I fully understand reporting if a child has been injured or harmed. This will automatically give us a substantiated non-compliance.
Page 19 line 614
Child records and other items specific to individual children are only available to personnel, as necessary, and the individual child’s parents. So am I no longer allowed to list the names of the parents I need to see on the door? The parent name is specific to the individual child?

Page 27 Line 829

Vehicle insurance. Proof of insurance indicating specific vehicles and individuals covered on the policy.

This regulation does not take into account FLEET INSURANCE.

Page 89 Line 2466. Chocolate milk.
The food program promotes the use of flavoring to encourage the consumption of the milk. Not allowing chocolate milk will ensure more milk is thrown away instead of the children drinking it.

Page 105 Line 3028
On or after November 1, 2013 have at least 40 square feet of floor space per infant in classrooms routinely designated for infants only. It should remain 35 square feet per infant unless it's new construction. This regulation can affect the number of children I care for in my program which becomes a long term cost factor.

Page 27 line 841
Transportation itinerary. Indicates approximate vehicle location at all times
Available in vehicle? What’s the purpose? If you’re in the vehicle you know where you are.

Page 27 Line 844 – 850
Transportation attendance maintained for 120 days in the vehicle? Why in the vehicle, why micro manage the location of storage?


Page 27 Line 847 What is another method of checking the vehicle instead of attendance?
Explain the two methods besides attendance?

Page 32 Line 960 High risk activity permission and plan
Plan is provided to parents and signed parent permission is obtained prior to activities and documentation of both are maintained for at least 12 months from the activity. Permission may be for each time the child participates or a general permission etc. Qualified activity person? More clarification. There needs to be a more specific definition. I can see this being used to get rid of activities just because licensing doesn't like them. If child care doesn't give them the life experience than who will?

Page 36 Line 1039
Drivers who have entered a plea of guilty or nolo contendere (no contest) been convicted of driving under the influence of alcohol or drugs or another impaired driving offense within the last five years. Drivers only? Need definition for drivers. Or current employees?

Page 39 Line 1113 – 1122
It is too subjective. Much of this is best practices and not something that can be regulated. For example part d of the section line 1121 says : Demonstrate realistic expectations for behavior … who determines what is realistic or not. (object b, c and d of section)


Page 40 line 1166
45 days to complete ELCCT
Not realistic. Many individuals have to rely on the public library. It's difficult to get this complete in 90 days let alone half the time.


Page 43 Line 1222 & Page 45 line 1276

Is not a director or master teacher at another program that operates concurrently at any given time. I understand them not being counted as a master teacher during the same work hours. Just reword to make it obvious that it isn't at the same time.

Page 49 Line 1375 What will be licensing approved food service training?

Page 53 Line 1468 – 1473
Calculating licensing capacity. The new language could change the intent. Does it change the intent? Could it be misinterpreted and why weren't the changes not documented i.e. highlighted. (As many of the items weren't highlighted as changes)

Page 55 line 1500 at least one teaching personnel from each group is present in the classroom. Need clarification

Page 59 Line 1604 – 1676 (Section 288 – should be removed)
Atmosphere

Too subjective, not enforceable. You can’t regulate best practices. Section needs to be removed in minimum standards but retained as a handout

Page 67 line 1886
Higher risk activities. If children engage in activities that increase their risk for severe injuries, such as swimming, shoreline activities, archery, ice or roller skating, gymnastics, enclosed inflatable bouncing equipment, or karate, the requirements in this section are met. Define what high risk activities are, not such as … Give a definite list not something that is subject to each licensing workers views.

Page 67 line 1893 Ratios and supervision. Teaching personnel required for the ratios are present with the children, including when the activity is conducted by contracted non-personnel. Additional personnel may be required, depending on the activity’s risk-level, to ensure proper supervision and care of all children. Clarify with definite activities.

Page 78 Line 2142,
Parent Input. The parents are included in ongoing program and policy development.
This is an accreditation requirement and you are putting in a policy for minimum standards.


Page 83 Line 2304
Swaddling infants birth : birth through two months of age with an infant-sized, thin fabric, such as a receiving blanket, is acceptable only when
Requested by the parents and permission is maintained. This is taking choice away from the parents. If they want their six month old swaddled because they won’t stop crying. A preemie should allowed to be swaddled. Which I'm sure they will be with a doctor's note but how many times do we need to send parents to the doctor for a note?

Page 101 Line 2920
Used by children six years of age and older provide privacy. Doors are placed in bathroom stalls (cost). I know of centers that removed the doors because licensing said it was a supervision issue.

Page 103 line 2990
Individual carbon monoxide alarms
This is an additional cost to the program.

Mixed age group chart
Requiring a three year old to be in a two year old class makes it so challenging to transition a child. This is the only age group that requires an older child to be present in order to bring in a younger child. If it could allow a child over twenty two months to count as a two year old for the purpose of transitioning.
Pg. 90 Line 2503
Family Dining
Family dining for young three year old children is unsanitary. Even with much guidance children will cough and sneeze in the food container. I know it is important to teach children to eat healthy food and to have good table manors but not at the risk of spreading illnesses. I think anyone in the health industry would agree with me. It is difficult to keep children healthy. We should not contribute to the spread of germs.

I think they need to quit making changes, its hard enough to keep up with everything, i think alot of their regulations are getting alittle out of hand, there will be alot of child care centers and homes shutting down, because its just not worth it anymore, then what will they do, the public school dont have near the rules we centers do, they have subs from off the street without taking all measures we do, they have way more students per one teacher in class, they dont document every little thing, and they can give choc and other flavors of milk, its just all over whelming, we dont have the gov paying our bills, we have to put up with parents trying to skip out on payments, people getting cut off assistance, then were stuck with paying all out with know help. I just think enough is enough, the stories about abused kids on tv all the time is always from in home dc, they need to focas more on them and not the centers....

I read the changes and some are good but then others not so good. We all need to remember that we are in this business for the children and to do what is best for them and their families

P.13 LINE 400 If you want an emergency plan for lockdowns this should be implemented by each county licensing agent who knows the area and can provide plans for all centers in their area. This goes for relocation facilities also. If a center has to relocate, I'm sure it would not meet the minimum standards required by licensing, so the licensing specialists should be responsible for providing alternative locations that would be suitable for emergency situations.

p.18 ine 579. Parents must be notified immediately if a child is not present at the pick-up location as scheduled. Other children on the van/bus should not have to wait while parents are called to verify the where abouts of children who are not at the designated pick up location. This could be reworded to say that within 10 minutes of returning to the facility parents will be notified. Generally these are school age children that are not at the pick up location and other children's care should not be neglected due to lack of communication from the parent of the missing child. (generally the case)

p.27 line 847. Give examples of two methods of inspecting. If you visually check, why is 2 methods required? Just to make things clear, provide methods that we can choose from.

p.35 line 992 It is difficult to find people in rural areas that will work for minimum wage. Usually you cannot replace an employee immediately. If you have to wait fingerprinting results and an individual cannot be left alone with children, then how can small town centers be withing licensing standards and keep child staff ratio? Besides fingerprinting staff is not going to give you any other information than that OSBI already has. Try drug testing everyone and DHS pays for it. This is just more work for us and its going to be discouraging to centers and new employees, having to wait on more paperwork.

p.36 line 1040, if an employee has a DUI are you saying they can't work in childcare for 5 years? I know plenty of people who work in prominent career positions who have had DUI's and they are not being punished for that length of time.

p.39, line 1132 A PDL within 1 month of employment. Most people don't even know what they want for themselves in 3 months, let alone one year? WHY???
p. 40 ELCCT. Most people quit within 90 days of employment. To require a new staff to invest in OSBI, fingerprinting, ELCCT class, before they even get a month's pay, is a little discouraging for childcare workers. Some of the money that goes for training vouchers could be used for the ELCCT or even the new ELG training. Give us to help here. Money out and not enough money in equals = daycares out of business.

p.43 line 1220 With all the requirements for staff, why doesn't the Director have to meet the Oklahoma PDL certificate?
p.66 line 1872 can you just say, personnel do not use cell phones or other media for personal use. . . .


Concerning screen time, Centers who are open early and stay late should not have to turn the TV off just because there is a child under 2 in the room. We only have TV during in the morning time and 30 minutes before closing. This is a mixed age group in a rural area. Just because the TV is on, doesn't mean an/infant or toddler is watching the TV. This is unfair to small rural centers who have limited staff.

P. 73 line 2027. Children who live in rural areas of Oklahoma or in other areas, should still have the right to have special visits into their classroom as a learning opportunity. Saying baby chicks cannot be permitted is to say children can be deprived of learning about the life cycle of animals and their habitat. Teach proper hand washing, don't deny the learning opportunity.
p.73 line 2022 are you saying fish is not allowed?
P.77 swaddling - each and every infant/child is different. Parents cuddle, swaddle, use blankets, etc with their children. The more we can immediate what parents do at center, the more consistent we can be in turn, help the parent and child. Taking away a blanket or swaddling an infant does not promote consistency and security to any child. .
p.81. How safe is it to leave an epi pen and rescue inhalers in the room with children and still have a staff member participate in the children's activities. What do you have to do wear a backpack everywhere to be able to immediately administer these med's when/if needed? This maybe could be limited to off site or field trips and or within 200 ft of where epi pen/inhalers are maintained in a safe and secure place away from other children, without burdening the staff of carrying 5-6 inhalers at all times.

p.83, 2317. I can't sleep without a blanket or sheet, why should an infant be required to NOT have a blanket. I understand thick heavy blankets, but lets face the facts, infants and young children use blankets as a security and to take that away is wrong.
p.83 2312 Some young children do not sleep in anything except bouncers, swings, etc while they are at home, why should they're move the sleeping child if they are comfortable and do not sleep well in a crib? There are exceptions to all children. I'm not saying allow all children to sleep outside their crib, but some children are just not good sleepers and require that they not be moved or they will wake up and cry for hours on end. That's like saying if you fall asleep in your recliner, you have to move after 20 minutes.(and you can't have a blanket!)
p.84 line 2347 are you saying we have to provide a pillow and case for each child. Who's going to pay for all these and where will they be stored?

p.89 line 2458 CACFP guidelines should be followed, which is recommended serving whole milk, but not mandatory. AND some children DO NOT drink white milk. Wouldn't it be better to serve Chocolate milk rather than have a child dump it out and have NO MILK AT ALL, ESPECIALLY OLDER CHILDREN.
p.90 line 2503. FAMILY STYLE MEALS, this is a great idea, but clearly not feasible for all centers. Leave it to the accredited centers who get a higher reimbursement rate. They can afford to have extra staff for cleaning more that lower income counties that are at a 2 star status and gets less income.

p. 91 line 2538. Come up with a great way to ensure children do not share their spill proof cups and I'm sure we would all agree to it.
P 96 line 2750 Have a designated location for each thermometer. Come up with way of placing thermometers all on the top left hand side of the refrig/freezer, and I'll be glad to accommodate your request. be real, those things get moved on a daily basis. there is no way to have them all in the exact same spot so your licensing workers don't have to hunt for them.
p.102 line 2941 Older centers who use an existing kitchen without 3 sinks should not be required to remodel their kitchen. There should be an exception for centers who have converted homes/buildings into centers without commercial kitchens. Now if you want to provide the funding to overhaul and remodel kitchens that would be up to your standards, I'm sure all of us smaller, older centers would appreciate that. Otherwise, I think your going to see centers closing, because we can't afford all the updates that are being mandated.
p.105, line 3028. requiring more and more square feet per infant is going to cause centers to not take infants at all. There is no money to be made in the infant rooms as it is.
p.110 line 3211 Play yards, playpens, etc, are easily put up and taken down to allow flexibility in centers whose enrollment varies. Smaller centers with mixed age groups need the flexibility to meet the needs of the children enrolled. These playpens are safe when used correctly and should not be taken away from smaller centers.

p.111 line 3262. equipment is part of what children need. Taking the equipment out of the licensed capacity is be unrealistic for all centers and or daycare homes.
p.115 line 3334. Need to define what cleaning products can be used. does that mean Windex or pine-sol is ok or not?

MIXED-AGE GROUP CHART: If it is ok to have a 1:8 ratio with 2 infants you should NOT have to have a 3 year old with 1:8 ratio with 1 year old's and older. You are PUNISHING THE 3 year old by having to put a 3 year old child in with the 2 year olds to have a staff ratio of 1:8 with no more than two 1 year olds. TO PUT THE THREE YEAR OLD IN A GROUP TO MEET RATIO STANDARDS IS UNFAIR AND IS MORE HARMFUL TO THE THREE YEAR OLD CHILD. IF THERE ARE NO INFANTS, THE 3 YEAR OLD SHOULD NOT BE REQUIRED TO BE IN THE CLASS TO MEET STAFF RATIOS.
THIS IS A TOTALLY UNFAIR AND IT IS DEVELOPMENTALLY INAPPROPRIATE FOR THE 3 YEAR OLD.

What happened to all my comments I posted last night?????

I agree with many of the comments made It is getting more and more difficult to keep up with the changes. I am very appreciative of my staff they work very hard to care for each child and maintain good relationships with parents. I am concerned that these amazing teachers will just throw in the towel and go work for better money somewhere else. More stress on the teachers and staff is not promoting better care. The majority of these changes are best practices and accredidation standards and very hard to regulate. Lets leave accredidation to those that want to be accredited and best practices to us making goals. All centers are not the same and owners and directors should be able to make changes that best suit their centers.