Never attribute to malice that which is adequately explained by stupidity.– Hanlon’s Razor
So March 15th our daycare closed in response to the corona virus. Then a few weeks later we got a message from our daycare that they would be open on a very limited-restricted basis. I figured it wouldn’t last long, and the daycare closed again citing rules from the DC Office of the State Superintendent (OSSE), which has oversight over schools & child care centers, that were impossible to follow.
I got a hold of those OSSE rules. Most made sense, but several seemed like they were written by someone with no practical knowledge of children or child behavior.
Then I compared those rules to the CDC’s Guidance for Childcare Programs That Remain Open. Yup, OSSE’s rules were written by an idiot, or an intern, or maybe a childless lawyer.
Let’s review shall we? These are the OSSE rules shared with me, I’ve italicized the stupid:
- All staff & children above 2 years old must wear non-medical face coverings at all times
- One staff member has to be at the door to receive children or go curbside
- All surfaces must be cleaned, sanitized, and disinfected after each use
- Staff must bring clothes to work to change every day before the start of work
- Children & staff must be 6 feet apart at all times
- Staff are not allowed to hug the children
- Staff & children must wash their hands for 20 seconds every 20 minutes
- Staff & parents [should be] aware of the requirement to check their own (or their child’s) temperature 2 hours or less before arrival to the facility each morning
- Staff are to wear clean, large, button-down, long sleeved shirts when working with infants and young children.
- Parents are required to wear non-medical face coverings when picking [up] and dropping off children
- Signs posted in every classroom throughout the building with reminders regarding cleaning, disinfection, and sanitation, as well as hand hygiene
Of the 11 rules, 3 are stupid, so stupid all cannot be practically followed. And when looking at CDC’s guidance, they are horrible misinterpretations. Let’s compare:
Face Masks for Kids
OSSE: All staff & children above 2 years old must wear non-medical face coverings at all times.
CDC: Cloth face coverings should NOT be put on babies and children under age two because of the danger of suffocation.
and
When feasible, staff members and older children should wear face coverings within the facility. Cloth face coverings should NOT be put on babies and children under age two because of the danger of suffocation.
Notice the difference between what OSSE says and the CDC. The CDC is mainly saying don’t put masks on children under 2 because of the high risk of suffocation. It appears it got interpreted by OSSE as put masks on everyone over 2. I’m not 100% sure the danger of suffocation is non-existent for the 2-5 year old set. Also, we know for a fact 4 year olds like to rip off clothing. Shoes. Socks. That sort of thing. Many adults working in industries or conditions find protective masks irritating after several hours, and will take them off, I have my doubts the 2-5 year olds will have a greater tolerance.
There is a phrase in all the stupid OSSE rules, “at all times.” Sometimes it’s the part that makes a reasonable rule, stupid. The CDC says that staff and older children (not really defined) should wear cloth face coverings “when feasible”, providing opportunities for meal times and other incidences when face coverings are not feasible or practical. The CDC’ “when feasible” provides more leeway than OSSE’s phrase “at all times,” which I can only imagine means mealtimes and nap times (opportunities for suffocation and partial ingestion of loose cloth– remember this covers the nose & mouth).
Social Distancing at the Childcare Facility
OSSE: Children & staff must be 6 feet apart at all times.
CDC: If possible, child care classes should include the same group each day, and the same child care providers should remain with the same group each day. If your child care program remains open, consider creating a separate classroom or group for the children of healthcare workers and other first responders. If your program is unable to create a separate classroom, consider serving only the children of healthcare workers and first responders.
and
Consider whether to alter or halt daily group activities that may promote transmission.
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- Keep each group of children in a separate room.
- Limit the mixing of children, such as staggering playground times and keeping groups separate for special activities such as art, music, and exercising.
- If possible, at nap time, ensure that children’s naptime mats (or cribs) are spaced out as much as possible, ideally 6 feet apart. Consider placing children head to toe in order to further reduce the potential for viral spread.
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and
It is important to comfort crying, sad, and/or anxious infants and toddlers, and they often need to be held. To the extent possible, when washing, feeding, or holding very young children: Child care providers can protect themselves by wearing an over-large button-down, long sleeved shirt and by wearing long hair up off the collar in a ponytail or other updo.
There are several examples where the CDC propose the 6 feet of separation, during the pick up and dropoff period, temperature screening and naptime. I have failed to locate in the CDC guidelines anything close to the OSSE’s rule of staff being 6 ft. away from children at all times, which creates another safety issue. The OSSE rule makes no exception for toddlers who need close (less than 6ft) supervision, especially when they are mobile and attempting suicide via exploring their environment. Once again the CDC provides greater leeway than the OSSE.
Our particular daycare has several separate rooms that would allow mixed ages but separate spaces for children of 1st responders and other kids.
The OSSE rules appear not to allow for kids to be in groups, but the CDC does.
Lastly, on this point, outside of a Soviet orphanage, who does childcare at a 6 foot distance? If this was a temporary measure of a few days, less than a week, fine. Longer than that and there are some childhood developmental and behavioral issues (see institutional autism) that could crop up for some population of children. Logically when the economy starts opening up, some of these rules are going to remain in place in order to head off the second wave. And if all the stupid rules remain in place, then daycares cannot remain open and be in compliance.
Wash Yo Hands
OSSE: Staff & children must wash their hands for 20 seconds every 20 minutes
CDC: All children, staff, and volunteers should engage in hand hygiene at the following times:
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- Arrival to the facility and after breaks
- Before and after preparing food or drinks
- Before and after eating or handling food, or feeding children
- Before and after administering medication or medical ointment
- Before and after diapering
- After using the toilet or helping a child use the bathroom
- After coming in contact with bodily fluid
- After handling animals or cleaning up animal waste
- After playing outdoors or in sand
- After handling garbage
- Wash hands with soap and water for at least 20 seconds. If hands are not visibly dirty, alcohol-based hand sanitizers with at least 60% alcohol can be used if soap and water are not readily available.
- Supervise children when they use hand sanitizer to prevent ingestion.
The CDC guidelines on handwashing are something that should be done anyway, virus or no virus. My only concerns would be with drying out infant skin if interpreted to include them. But OSSE’s rules would have adults and children trying to wash hands 6ft apart constantly all day…. while wearing face masks.
Conclusion
I don’t know how long this is going last, and if things open this Summer, they’ll close back down for the 2nd wave, which tends to be worse than the 1st. I don’t expect to get back to life as it was in 2019. But I would like my daycare to open back up so I can get back to work and it (and the schools) can’t open up if OSSE insists on keeping unworkable rules that have less leeway than the CDC.
Yes, I care about my son’s safety, which is why I looked at the CDC’s webpage. If the daycares cannot open, then I guess we’ll be looking for a nanny, and that has it’s own issues.
You can contact the OSSE and ask about their rules their email is osse@dc.gov or you can fill out the Ask the Superintendent of Education form.