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Daycare and preschool providers in Arlington are decrying proposed new child care regulations as overly onerous and intrusive.

A 34-page draft of new child care center regulations would set stringent requirements for employee education, require food handling certificates for handing out snacks and would require providers to encourage mothers to breast feed, among numerous other regulatory provisions.

Child care providers — particularly small, part-time operators — are speaking out against the the changes to Chapter 52 of County Code via the county’s online “open comment tool.”

“This document was supposed to clarify things, however, it created more issues,” said one comment.

Many comments focused on new education requirements for the teachers and assistant directors at child care centers. They would have to have a Bachelor’s Degree in education or a similar major and “at least 9 semester credits of advanced study in child development or early childhood education.” Current teachers would have three years to meet that requirement.

The education requirement could financially burden employees, who may have to go back to school to get the necessary credits, and could burden child care centers by raising the cost of hiring new employees,  providers said.

“Have you considered the impact this would have on preschools and just how difficult finding teachers with these very narrow qualifications will be?” said one comment. “As former preschool board member who was in charge of hiring for two years, I can tell you that finding highly qualified teachers who are willing to work for preschool pay is already very challenging. You add these new rules and and two thirds of our EXCEPTIONAL staff would not be qualified to teach.”

“I am sure these regulations are well-intentioned and meant to foster excellent Arlington preschools,” said another. “But we already have excellent Arlington preschools. The effect of some of these costly new requirements will be to drastically increase costs, making these excellent schools inaccessible financially for some area families.”

Providers also questioned a requirement that they have a certified food handler on staff if they serve or store food.

“If we need to obtain a license for teachers to distribute Goldfish crackers, this would be unduly burdensome,” said a daycare provider. “We are a part-time center and children are required to bring their lunches from home. The only food we give them are snacks and milk for lunches, if requested.”

Operators of part-time cooperative preschools and daycare centers, which are run largely by volunteers, said that such schools should be exempt from the provisions. Staffing requirements that require specific child-to-adult ratios but only count paid staff, while also prohibiting volunteers from being alone with children, would make it “virtually impossible for parent cooperative preschools to function,” said one commenter.

Some of the most incredulous commentary was reserved for provisions that daycare providers viewed as unnecessary for child safety and overly prescriptive. Among them:

• “The licensee will ensure that mothers are encouraged to breast feed their infants.”
• “The interior of the building must be finished in light or bright colors…”
• “Celebrations (birthdays, special occasions) should include mostly healthy foods or non-food treats.”
• “Children two years of age and older will be served only skim or 1% pasteurized milk.”
• “Staff will promote dental hygiene among children at mealtimes.”
• “Only full-strength (100%) pasteurized fruit juice or full-strength juice diluted with water from a cup will be served to children twelve months of age or older.”
• “… All cribs, cots and mats must be spaced a minimum of 3 feet (36 inches) apart.”
• “[Providers must have a plan for] acquiring, stockpiling, storing and cycling to keep updated emergency food/water and supplies needed to care for children and staff for up to 3 days if shelter-in-place is required…”
• “The licensee will ensure that a trained staff member shall conduct and document a health check of each child every morning upon arrival.”
• “In addition to the application document, the [child care center] must submit… a business plan.”
• “A licensee will have specific arrangements with a health care provider who will provide consultation on both routine and emergency health care issues for children.”

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