Public comments for: Amendment of School Based Programs for Children Ages 3-5 (Article 43 of the NYC Health Code)

Comments

Comment:
I would like to share my concerns pertaining to a proposed change to Article 43 pertaining to daily tooth brushing. I understand the rationale behind the addition of this regulation, but for those who have to actually implement this policy there are several concerns: • It places an unfair burden on classroom teachers. • It is time consuming. What will the children lose programmatically to allow for this? • The responsibility of managing the logs and properly sanitizing the toothbrushes. • The responsibility of knowing which children are allowed to use fluoride toothpaste, which have non-fluoride toothpaste, and which children’s parents have opted out of this. • The actual assisting of young children with the process of brushing their teeth. What will this look like during the separation stage in which the children are only beginning to trust the adults in their classroom and transition to the routines of school? To what degree must we insist on them participating in this routine? • The burden of the supplies required on a daily basis. • The additional exposure to germs, both for the children and the teachers. Thank you for your consideration regarding these objections to the adoption of a regulation requiring programs to implement a tooth brushing routine.
Agency: DOHMH
Comment:
There are many pros and cons to this Proposal. Teaching young children to care for their teeth is a pro, but more staff must be added. It will take a long time to have 18 children brush their teeth properly. The teachers and staff are under the time requirements each day and adding another "activity" will add to that. Oral hygiene practices are very important. The DOE should begin to work hand in hand with Dental Schools to bring students in to address oral hygiene with the students and parents.
Agency: DOHMH
Comment:
As a director of a Pre-K For All program in Queens, I am strongly against this proposal. Taking even more time out of instruction to brush the teeth of every child in our program is outrageous. While I can understand that there are many children who require assistance in brushing teeth and families who need assistance with maintaining the oral hygiene of their children, it is not the school's responsibility to take this on. We instruct children in oral hygiene, particularly during Dental Health Awareness Month, but to make this a regular part of our schedule is unreasonable. Instead, resources should be provided to parents. Why not send in one of these pediatric dentists who have commented their support on here to do a dental screening in the schools? If a child is found to be in need of more dental care, a referral can be sent home to the parent recommending treatment. Perhaps it can include a list of dentists that are willing to treat low income families. Are there any? If this amendment IS put into effect, there should be an option for parents to opt out. I know I would.
Agency: DOHMH
Comment:
Prevention is a key component in making hedge way to reduce caries prevalence, and because of this, I firmly support having a supervised toothbrush program for children. There have been some studies that indicate that children who have toothbrushing implemented in their education at school, developed less caries than children who didn’t have such programs. Here is one such study https://www.ncbi.nlm.nih.gov/pubmed/15741722. It’s my conjecture that these types of initiatives not only teach children to have better oral hygiene, but it makes it fun for the kids when done in a group setting! In essence, this sets the foundation for a more positive attitude towards oral health, and ultimately hopefully an impact in caries development.
Agency: DOHMH
Comment:
I am writing is support on the proposed rule change for assisted brushing in schools. Other states such as MA have been doing this for years. Dental caries is the number one chronic disease and leads to many missed school days and work days for parents and a large cost to health care budgets for treatment. Just as children in school practice hand hygiene, oral hygiene should also be done as students spend a large part of the day in school. Many children receive inadequate supervision at home and lead to dental cavities, tooth loss, pain and other issues. Numerous studies from around the world have shows that assisted tooth brushing at school decreases dental cavities and can reduce dental disease, missed days from school and work, and reduce costs to the city. I support the proposed rule change,
Agency: DOHMH
Comment:
After carefully reading the proposals. The ideas presented have their pros and cons. The pros/cons are: 1. I think more staff development hours are essential and crucial. The development of children is rapidly changing, and we as professionals should be informed. 2. Toothbrushing is something I use to do in Head-Start and I am okay with it since that was a requirement. however, according to DOH, they are making this a requirement with private day-cares. My questions are who will supply these items (toothbrushes, toothpaste, cups)? How often will this need to be done (i.e. breakfast/lunch)? What kind of training is going to happen for families about the importance of toothbrushing? What penalties will we have if parents do not want their child to have their teeth brushed at school? 3. Epipen, I think this something that is to be used for children with prescription only. Carrying one in the school building should be something to pay close attention to. We have to keep in mind the cost of them after expired date etc. These are just items I am thinking of off the top of my head that she be considered.
Agency: DOHMH
Comment:
I write the following on behalf of the UJO of Williamsburg and North Brooklyn, which represents the yeshiva schools in the Williamsburg area. About 2,240 preschool children between the ages of 3 to 5 are enrolled in our schools' child care programs, and will be affected by the proposed amendment to the Article 43 regulation. At least 80% of the students reside in low income households. 10 years ago we worked closely with DOHMH on a new set of health and safety regulations, Article 43 for school-based child care programs. I want to thank the New York City Department of Health Bureau of Child Care for working closely with the schools to ensure the wellbeing of our children. The proposed amendment to require a daily tooth brushing program, runs contrary to the spirit of Article 43, which focused only on health and safety issues, but not curricula or educational programming. While we share the Department’s goal to promote good dental care and hygiene, we are opposed to the proposed new requirement because: • The proposed amendment language includes the following “(2) School-based programs shall have children brush their teeth while seated or standing around a table.” Brushing above a table, in groups, without a sink nearby - unlike smaller centers, in school-based programs the sink is often across the hallway - this is a recipe for the spread of germs. While this is a concern for the whole year, it is especially serious during the flu season. Three and four year old children are just learning about how germs are spread and personal hygiene. A child could be contagious one day before symptoms appear. It is unrealistic to expect a child with a cold to turn the other way to cough. Preschoolers are not great at using Kleenex or covering their mouths. How many teachers will be in the room with the teacher monitoring their every move? • The additional cost to the schools' strained budgets - much of them struggle on a daily basis to cover the rising costs to operate these program - may eventually have to be passed on to the parents, overwhelmingly low-income families; • While we appreciate the department's role in assuring the safety and well-being of the It creates a precedent of government regulating private programs' curriculum. The UJO has collaborate with DOHMH for years combating outbreaks of shigella, measles, chicken pocks, lead poisoning, and to promote healthy eating and living among children, adults and seniors. We strongly belief that tooth brushing ought to be the primary responsibility of families. Schools can play an important role here with raising awareness of the importance of daily brushing, and we are willing to work with the department to promote better oral care and hygiene. Our schools want to keep parents involved in their children’s well-being. However, there is a big and onerous leap from educating students and a mandatory daily brushing requirements, which presents health challenges.
Agency: DOHMH
Comment:
As a director of an early childhood program, we are not for tooth brushing within our preschool classrooms. We do demonstrate to children good practices for brushing their teeth; however, physically brushing every child's teeth after all meals will be time consuming. We try our best as educators to fit the curriculum into the allotted time each day and to ensure that we are imparting the knowledge students need to succeed in the next grade. I do believe that tooth brushing is solely the responsibility of the child's parent. It is a parent's job to ensure that their children are brushing their teeth properly and going to the dentist regularly. Furthermore, I agree with a comment posted earlier - some habits and practices of children ages 3-5 can be very unsanitary and a group of preschool children brushing their teeth can be very unsanitary.
Agency: DOHMH
Comment:
As a parent of two children and someone who works in Early Childhood education, I am opposed to this proposition. As another poster commented, I can only imagine the hygiene and contamination issues that this will bring forth, not to mention the time it will take away from the teachers' schedules to accomplish this. As a parent, I know first hand that brushing a child's teeth can be physically daunting, especially if the child is uncooperative and may need to be restrained to accomplish the task. I am also not comfortable with other adults brushing my child's teeth. The idea of adding additional training now on how to brush a toddler's teeth to the growing number of items teachers are responsible for in an already overloaded day is completely absurd.
Agency: DOHMH
Comment:
I am a pediatric dentist in private practice on the UWS - it would be wonderful to promote oral health in this way as caries is a largely preventable disease. I would hope that toothbrushing in day cares is done in conjunction with hand hygiene so as to avoid the aforementioned spread of communicable diseases (like the flu) and also done in conjunction with nutritional counseling and oral hygiene instruction for children and families as caries is a multifactorial disease.
Agency: DOHMH

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