Notification of Training Approval and Regulation Changes November 6, 2009 The State Bureau of Child Care Licensing recently underwent a rigorous review of the Nevada Administrative Codes (NAC) pertaining to the Services and Facilities for Child Care (Chapter 432A). Several outcomes of that process have direct implications related to training approval. The purpose of this letter is to notify you of changes related to the initial courses of training required within 90 days of new employment; CPR, 1 st Aid, Child Abuse and Neglect, Signs and Symptoms of Illness and a newly added training; Sudden Infant Death Syndrome (applies only to caregivers working with children under 12 months of age). Please note that this letter addresses the changes for ALL of the above mentioned training topics. While we recognize that you may not train in all of the topics that will be addressed in this correspondence, it is more efficient to notify all trainers of the changes all at once. Therefore, we ask that you pay particular attention to the topics that pertain to you. The corresponding regulation is referenced for each change noted below with the new/revised language highlighted in yellow. To view either regulation in its entirety, please visit http://www.nevadaregistry.org/resources/licensing.html. Revised Adopted Regulation R112-06 Bloodborne Pathogens/SOI Inclusion of Bloodborne Pathogens in Signs and Symptoms of Illness (SOI) Training NAC 432A.308. Section 41. Subsection 2 (Page 35) The training for the recognition of signs and symptoms of illness must include, without limitation, the provision of information concerning health and the observation and evaluation of signs and symptoms of illnesses and responses to illness and emergencies and training in the prevention and exposure to bloodborne pathogens. The training for the administration of first aid must include, without limitation, the administration of first aid to victims of fire, serious injury and the ingestion of poison. Change: Bloodborne Pathogens was not previously required as part of SOI training. Beginning April 1, 2010, all training approval requests for SOI training must include information on Bloodborne Pathogens in order to be approved by the Registry. Both trainings must be provided by a licensed health care professional. 1
Providing first aid in situations where blood is present is an intrinsic part of a caregiver s job. Split lips, scraped knees and other minor injuries associated with bleeding are common in child care. ( Caring for Our Children National Health and Safety Standards, page 28). Training Approval Implications: The regulation does not stipulate the length of the portion of an SOI training that must be concentrated on Bloodborne Pathogens. The Registry will look for evidence that the training content includes guidelines to follow when coming in contact with blood, bloodborne pathogens (Hepatitis B virus, HIV and Hepatitis C virus) and other potentially infectious materials in accordance with the standards of the Occupational Safety and Health Administration (OSHA). Why Both? Bloodborne Pathogens trainings typically cover the safety protocols for handling all types of bodily fluids and is geared toward the protection of the employee and the individual they are coming in contact with. SOI, on the other hand, helps child care providers understand and recognize communicable diseases and how they can be prevented. SOI is geared toward the identification of diseases, not the handling of bodily fluids. Implications for Caregivers: Caregivers who are required to take Bloodborne Pathogens to meet OSHA regulations at their place of employment (training offered separately from SOI as standalone training) will still be required to complete an SOI containing the required Bloodborne Pathogen content as dictated by child care regulation NAC 432A.308. Section 41. CPR Expansion of Automatically Accepted Service Providers NAC 432A.326. Section 43. Subsection 2 (Page 39) Also referenced in Revised Adopted Regulation R032-07-NAC 432A.322. Section 11. Subsection 4 (Page 10) Any training related to the administration of cardiopulmonary resuscitation must be taught by a certified instructor who meets the standards of a nationally or internationally recognized provider of training in cardiopulmonary resuscitation, including, without limitation, the American Heart Association, the American Red Cross, Medic First Aid International, EMS Safety Services, or the American Safety and Health Institute. Change: Previously, the American Red Cross and American Heart Association were previously the only automatically accepted providers for CPR (Registry-approval not required); all other instructors/agencies were required to submit each CPR/First Aid training for approval through the Registry s approval process. As of April 1, 2010, Child Care Licensing will automatically accept training from any of the 5 approved agencies so long as the certification cards are issued by one of those approved agencies. In other words, CPR providers representing the organizations listed above are no longer required to obtain approval codes for each training offered. * Note: CPR/First Aid Instructors issuing certification cards with their own business name listed rather than using the certification cards 2
issued by one of the 5 approved agencies, must continue to submit training for approval and receive a unique approval code for each training offered. There are a number of reputable, nationally and globally recognized organizations offering CPR training with standards equivalent to those of the American Red Cross and the American Heart Association. The regulation has been expanded to be more inclusive of all such organizations. Training Approval Implications: Any instructor/agency that is not issuing certification cards from any of the 5 approved agencies must still submit training requests for approval. Representatives from the 5 approved agencies are no longer required to get each training approved but retain the option to continue to submit CPR/First Aid trainings (that are open to the public) to the Registry for posting to the website. CPR training must include Infant/Child CPR (Courses specific to adults will not be approved for child care training hours). Implications for Caregivers: Because fewer agencies will now be required to submit CPR/First Aid training for approval, caregivers will be less informed about the CPR training opportunities available statewide through the Registry s online training calendar (training inquiries regarding availability of CPR and First Aid are the most frequent received by the Registry). Note: Coming Soon! The Registry is currently developing a Trainer Directory. The directory will be available on the Registry website and will allow consumers of training to look for specific trainers with expertise in specific topics of interest. Trainers/Sponsors available to provide training and education to the ECE workforce, and who choose to be listed in the directory, will be able to do so for a nominal annual fee. The directory will contain information specific to individual trainers such as name, employer/business name, educational background, Career Ladder level, and eventually, trainer level (in conjunction with the development of trainer criteria). Basic contact information and areas of training expertise will also be provided. Implications for Data Collection: Fewer agencies will be submitting CPR/First Aid trainings for approval. As a result, the Registry will lose valuable data about the frequency, accessibility and availability of CPR/First Aid training. Implications for Trainers/Sponsoring Agencies: All approved trainings (open to the public) are automatically posted to our online training calendar - free of charge to you. Without Registry-approval, your business loses the benefit of free advertising. Again, though representatives from the 5 approved agencies are no longer required to get each training approved, they have the option to continue to submit CPR/First Aid trainings (that are open to the public) to the Registry for posting to the website. 3
Revised Adopted Regulation R032-07 Initial Training Requirements Definition of Number of Required Hours within Each Topic NAC 432A.323. Section 13. Subsection 1 (Page 14-15) Except as otherwise provided in subsection 4 and NRS 432A.177, within 90 days after commencing his employment or position in a child care facility.. (a) Any training required by the facility in which the director serves or in which the person is employed for the purposes of obtaining certification in the administration of cardiopulmonary resuscitation as required pursuant to NAC 432A.322; (b) Three or more hours of training in child development or guidance and discipline specific to the age group served by the facility in which the director serves or in which the person is employed; (c) Two or more hours of training in the administration of first aid (as per Revised Adopted Regulation R112-06 NAC 432A.308. Section 41. Subsection 2, page 35, the training for the administration of first aid must include, without limitation, the administration of first aid to victims of fire, serious injury and the ingestion of poison.) (d) Two or more hours of training in the recognition of signs and symptoms of illness, which must include, without limitation, training in the prevention of exposure to Bloodborne pathogens; (e) Two or more hours of training in the recognition and reporting of child abuse and neglect; and (f) If the person works with infants under 12 months of age, at least two hours of training concerning Sudden Infant Death Syndrome. Changes: Previously, regulations did not stipulate the number of hours required within each required topic (9 hours had to be obtained across all topics within the first 90 days of employment). Additionally, Child Development specific to the ages of the children in care and SIDS (if applicable) were not required within 90 days. Training Approval Implications: As of April 1, 2010, the Registry will approve training in the topics of First Aid, SOI, Recognition and Reporting of Child Abuse and Neglect and SIDS only when the training is at least 2 hours in length. The Child Development requirement can be met either by completing a single 3 hour training or by combining several trainings to equal the total required. As a result, the Registry will continue to approve general child development trainings for any number of requested hours, so long as the training is at least 1 hour in length. As of April 1, 2010, all exclusive CPR trainings (CPR only) must be a minimum of 2 hours (the maximum number of hours that will be granted by child care licensing for CPR is 3 hours per certification). The regulation stipulates at least 2 hours for First Aid. As a result, trainers offering a CPR/First Aid combination class for 3 hours will no longer be approved. When CPR and First Aid are offered together, the training must be a minimum of 4 hours in duration (2 hours for CPR; 2 hours for First Aid). SIDS training must be provided by a licensed health care provider or person otherwise certified in the topic. 4
Implications for Caregivers: Whereas previously, 9 hours were required within 90 days of commencing employment, the new regulations require a minimum of 11 hours within the first 90 days, and 13 hours for caregivers working with infants. Implications for Trainers/Sponsoring Agencies: Regarding First Aid, SOI, Recognition and Reporting of Child Abuse and Neglect and SIDS: Because regulations now stipulate the number of hours required for these topics, it is recommended that trainers currently offering these topics for less than 2 hours, adjust their existing trainings to meet the minimum number of hours required by regulation. Training Approval Guidelines Regarding Initial Courses of Training This section is intended to provide trainers offering the initial courses of training (First Aid, Child Abuse and Neglect, and Signs and Symptoms of Illness) with guidelines for training content. The suggested guidelines are not written into regulation; they are being provided by the Registry simply to help trainers construct training in accordance with national health and safety standards outlined in Caring for Our Children: National Health and Safety Performance Standards. The Registry will continue to approve training in accordance with what is mandated by Nevada s state child care regulations but recommends that trainers consider incorporating the following guidelines into new and existing trainings to ensure caregivers are receiving comprehensive information as it relates to these topics. First Aid Training Revised Adopted Regulation R112-06 432A.308 Section 41. Subsection 2. (Page 35) Existing Language Regarding Content: The training for the administration of first aid must include, without limitation, the administration of first aid to victims of fire, serious injury or ingestion of poison. Training Approval Guidelines: In accordance with Caring for Our Children: National Health and Safety Performance Standards (page 23), management of a blocked airway and rescue breathing comprise two of the core elements of pediatric first aid training. In addition, the course must present an overview of the Emergency Medical Services (EMS), accessing EMS, safety at the scene, and isolation of body substances, and the first aid instruction that is offered shall include, but not be limited to recognition and first response of pediatric emergency management in a child care setting of such things as abrasions, bleeding, including nosebleeds, burns, fainting, poisoning, puncture wounds, injuries including insect, animal and human bites and more. First aid for children in the child care setting required a more child-specific approach than standard adult-oriented first aid offers. Knowledge of pediatric firs aid, including management of a blocked 5
airway and rescue breathing, and the confidence to use these skills, are critically important to the outcome of an emergency situation. Recognizing and Reporting Child Abuse and Neglect Revised Adopted Regulation R032-07 432A.323 Section 13. Subsection 1 (e). (Page 15) Existing Language Regarding Content: None Training Approval Guidelines: In accordance with Caring for Our Children: National Health and Safety Performance Standards (page 28), child abuse education and prevention should address physical, sexual, and psychological or emotional abuse, injury prevention, the dangers of shaking infants and toddlers, as well as signs and symptoms of sexually transmitted diseases. Training should help caregivers recognize visible signs of child abuse, including pattern marks, bruises in unusual locations, pattern or immersion burns, shaken baby syndrome and behaviors suggesting sexual abuse. Caregivers should learn about the mandated reporting requirements, the process for follow-up after making a report and the protection and exposure of mandated reported under the state s child abuse law. Education about the physical manifestations of abuse can increase the number of appropriate referrals to physicians and child protection agencies. Signs and Symptoms of Illness (Infectious Disease) Adopted Regulation R032-07 432A.323. Section 13. Subsection 1 (d). (Page 15) Existing Language Regarding Content: Two or more hours of training in the recognition of signs and symptoms of illness, which must include, without limitation, training in the prevention of exposure to Bloodborne pathogens. Training Approval Guidelines: In accordance with Caring for Our Children: National Health and Safety Performance Standards (page 8), training in the preventing the spread of communicable disease should include hand washing, sanitation, diaper changing, food handling, health department notification of reportable diseases, equipment, toy selection and proper washing, sanitizing to reduce the risk for disease and injury, and health issues related to having pets in the facility. Caregivers must be knowledgeable about infectious disease because properly implemented health policies can reduce the spread of disease, not only among the children but also among staff members, family members, and in the greater community. Please feel free to contact the Registry at (775) 448-5275 or (800) 259-1906 for more information and/or clarification regarding any of the above referenced training approval implications/changes. 6