For comments on the proposed indoor air quality regulations that will impact child care centers.The Department of Health and Senior Services (DHSS) has proposed new regulations for the testing of indoor air in child care centers.  A brief summary of the proposed regulations is below:Indoor air quality sampling will be required at most child care centers;
The projected cost of conducting the air quality sampling will vary greatly as many have learned from the preliminary assessments; estimates start in the thousands of dollars for an average size center;
A $1,500 fee is proposed to file the results of your initial test with DHSS;
A $450 fee is proposed for renewal if there are no changes in your building or any of your neighbors;
The $1,500 fee applies if there are changes, and the testing must be done again;
The statement of economic impact on the centers filed with the proposed regulations only addresses the filing fee, not the costs of conducting the tests;
The statement of job impact only addresses the centers that might close and the staff at those centers, not how the families who use those centers might be impacted.The New Jersey Association of Child Care Resource and Referral Agencies (NJACCRRA) has identified the following key talking points.  If you share any of these concerns, please include them in your comments to the Department of Health and Senior Services.Reduce the cost to the centers to file the test results with DHSS;
Determine an appropriate length of time for re-certification of indoor air quality (if it is tied to the renewal of the child care center license, currently every three years; there is proposed legislation to shorten that time period to one year);
It is not feasible for centers serving subsidized or low income families to pass the increased costs to the families they serve, increasing the likelihood that theses centers will be forced to close;
Child care subsidy reimbursements did not include a cost of living increase last year in spite of the increase in operational costs,
The preliminary assessments have added thousands of dollars in expenses to many centers; this will compound those costs;
If these regulations are to protect children, do not set a standard for children in schools that differs from those that govern children in child care centers (the proposed regulations only apply to schools if the school applies for a construction or renovation permit).  Imposing this requirement on centers operating in schools that are not required to do the testing sets up an inappropriate double standard, i.e. children attend during the regular school day, but the after-school program is prohibited from operating in the same building unless it meets air quality standards.

Your child care center will be impacted by these proposed regulations. Now is the time to speak up if you have concerns.  Written comments must be submitted by January 2, 2009, via regular mail to:

Ruth Charbonneau

Director, Office of Legal and Regulatory Affairs

Office of the Commissioner

Department of Health and Senior Services

PO Box 360

Trenton, NJ 08625-0360

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