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Finally, one commenter sought clarification as to whether prohibiting the use of bottles, cups and glasses during water table play in § 157.10(h), included the use of plastic cups. As recommended by Caring for Our Children, the rulemaking prohibits the use bottles, cups and glasses during water play because the presence of these items encourages children to drink from them. Contamination of hands, toys, and equipment in the room in which play tables are located may play a role in the transmission of diseases in child care settings so prohibiting items that can lead to contamination is necessary to ensure the health and safety of children in care.

Transporting Children One commenter requested OSSE provide further criteria related to supervision of transporting children, specifically the appropriate ratios during transport. Ratios during transport have been addressed. Subsection 121.2 specifically states that minimum adult-to-child ratios shall be maintained in vehicles during transport.

I. Additional Requirements For Licensed Centers

Child development centers must meet the all the requirements for all licensed child development facilities. In addition, licensed child development centers must meet the additional requirements set forth in Sections 162 to 166. The State Superintendent received four comments about child development centers.

Requirements for Center Directors Section 164 addresses the qualifications and responsibilities of Center directors. Specifically, § 164.6 requires that a center director complete twelve (12) hours of professional development annually. One commenter noted that Center Directors, who have been Directors for a long time, do not need to participate in annual professional development approved by OSSE. While OSSE values and recognizes the commitment to children of Center Directors who have been Center Directors for a long time, research has shown that coursework and training has a measurable and positive effect on quality child care. OSSE considered these comments, however OSSE has elected not to incorporate the commenter’s suggested changes. An individual’s experience as a Center Director must be supplemented by continuing competency-based training to determine and provide whatever new skills are needed to care for children in child care settings. Research, best practices, and knowledge base are constantly changing and it is essential that center directors, as the instructional leaders for the program, stay current with information. Maintaining the annual professional development requirements as set forth in the proposed rulemaking is consistent with the emphasis the CCDBG Act has placed on professional development which is designed to prevent harm to children and ensure optimal development and learning.

Teacher Qualifications One commenter appreciated the waiver in § 164.3 that applies to center directors who have served as a center director continuously for ten (10) years and requested that the waiver also apply to teachers who have served as a teacher continuously for ten (10) years. OSSE intended this waiver to also apply for teachers who continuously have served as a teacher continuously for ten (10) years, however that was omitted in the proposed rulemaking due to a drafting error. This provision is now in the final rulemaking in § 165.4 and the following sections were renumbered accordingly. Additionally, in reviewing the proposed rulemaking, OSSE recognized a drafting