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State Superintendent appreciates these comments and recognizes stakeholders concerns given that these requirements are a significant shift in the professional development requirements. However, OSSE will not incorporate any of the commenters’ suggested changes.
A comment requested clarification as to which trainings were required every single year, versus upon hire. As provided in § 139.6, annual training must include the health and safety standards listed therein. Another commenter requested clarification as to who would provide the training, the licensee or OSSE, and if the licensee, whether experienced internal school staff may provide the training. While OSSE itself will not provide the training, OSSE will widely publicize the availability of these health and safety trainings, including on-line and in-person professional development opportunities. Additionally, internal school staff may provide the training if school staff is an OSSE approved trainer pursuant to § 139.9. The federal regulations have emphasized the overarching importance of ensuring that staff members understand how to preserve the health and safety of children in their care. Recognizing that there may be a cost to obtaining trainings, ACF has provided several no-cost or low-cost trainings at this web site: http://eclkc.ohs.acf.hhs.gov/hslc/tta-system/health/ccdbg/ccdbg-required-health-safety- training.html. However, OSSE and ACF do not advocate the exclusive use of online trainings. A mixed delivery training system that includes both online and in-person trainings can meet the varied needs of staff members.
The federal regulations issued on September 30, 2016 required that staff members who provide direct care for children must be supervised until training is completed in pediatric first aid and CPR, safe sleep practices, standards precautions to prevent communicable disease, poison prevention, and shaken baby syndrome/abuse head trauma. In order to comply with this federal requirement, OSSE added § 139.4 and renumbered the following sections accordingly, which provides:
139.4 The following critical health and safety training must be completed before staff members are allowed to care for children unsupervised:
(a) Prevention of sudden infant death syndrome and use of safe sleep practices, as applicable;
(b) Prevention of shaken baby syndrome and abusive head trauma, as applicable;
(c) First aid and CPR;
(d) Poison prevention, including the handling and storage of hazardous materials and the appropriate disposal of bio contaminants; and
(e) Prevention and control of infectious diseases, including immunization.
This non-substantive amendment maintains the intent in the proposed rulemaking to ensure staff members are adequately training to care for children and to comply with the CCDBG Act’s implementing regulations.