Bump

Putting link to this study in here:

http://www.jacionline.org/article/S0091-6749(15)01915-6/fulltext

QuoteConclusions
The unpredictability of anaphylaxis is highlighted by the frequency of events with unknown triggers (21.6%) and of events occurring in individuals with no known allergies (25.0%). Results underscore the necessity for comprehensive preparedness training in US schools.

Threat is a double-edge sword.  You can also be banned from a campus and then you would indeed have to put that lawsuit threat to the test.  The existing case law is not exactly overwhelmingly in a parent's favor.  Threatening a law suit then actually financing one through a very possible appeal or two, not to mention the time commitment, typically drains families.  Schools usually have bigger coffers than families, and they now have a unified process for repelling "federal intrusions" in the form of OCR investigations.

The NSBA is also launching a renewed effort to fight back against Tustin.  I can't agree with your comment on liability.  They have liability regardless of what you sign.  Each state may have its own statutes that release identified personnel that are trained to administer epinephrine, and it may further state that self-carry is contingent upon child's doctor attesting that child can self-administer.

They are not released from in loco parentis, duty of care, ADA or 504, etc.  However, they also still have government immunity and qualified immunity, qualified immunity being nearly a "freebie" as long as whatever was done was done in good faith.

I'm not downplaying your role as a parent advocate, but I would say that it's unknown what combination ultimately led to the outcome in the 504.  The idea of threats via email is not something that would get results from many districts.  It may end in a ban from campus or worse.



Advocating under ADA is a protected activity -- within limits.  On that note: Retaliation claims and protected activities

I had that conversation with our school district. I sent them an e-mail threatening to sue under the ADA, informing them the Epipen would be on my child's person securely attached until their district figured out a policy that would prevent my child's death, and added "may God help the person who tries to remove it from her possession when I get to the school." I told her to scream repeatedly if anyone took it until they called me. Then I tied it in a case through her belt loops with yarn & sent her to school. That was two years ago (1st grade). No one said a word again. Then this year they finally established a 504 allowing her to carry with dr. authorization so at least they had paperwork and wouldn't be liable.  You just have to make them afraid of you.  E-mailing every article you see regarding another anaphylaxis death and copying everyone from the teacher to district to State board helps, too. I think eventually they get annoyed enough they pretend you don't exist.  Good luck.

Florida -- see (3) I.  Entire section on epinephrine.

http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&Search_String=&URL=1000-1099/1002/Sections/1002.20.html

Florida -- this appears to be some legislature that governs but seems to apply only to the stock epinephrine:

http://www.flsenate.gov/Session/Bill/2013/0284/BillText/er/PDF

Florida -- possible direction and person to ask as to how to change policy?

http://www.fldoe.org/bii/CSHP/

Bumping and wanting to try to get a list in here of states and school districts that STILL have law or policy on books that have a "meds must be locked" rule which means the epinephrine is STILL locked up (with key) and not readily accessible.

Some states and/or parts of states that I think are still of concern:

California
Florida


~~~~

PLEASE feel free to add to this list!  Post as guest if you want to not be associated with particular location.

BUMP!

State-by-state -- see the legislation and suggest reading for own state . . .

also, note which states still do not have this protection!


http://www.aanma.org/advocacy/meds-at-school/

More follow ons

Mezzo

QuoteI'm dealing with a similar situation, so I appreciate your efforts to gather this info together.  DD's Dr. did write a letter stating that she needs to be no longer than 60 seconds away from access to an Epi, and that she cannot administer it to herself.  I'm hoping that will be helpful to our case, along with that joint statement by FAAN, NASN, etc., about Epis not being locked up.  My school claims that since the keys are always on the nurse's desk, locking the cabinet is fine. 

ajasfolks2

Quote
I ponder these things:

The staff who refuse to recognize that a lock may malfunction WITH NO NOTICE and at EXACLTLY THE WRONG TIME need to be educated.

If locks and keys were foolproof, why do locksmiths exist?

Are these staff members handy with a fire ax so to be able to open the cabinet via other means?

And exactly how long will that Epipen-extrication take while the child's ANAPHYLACTIC REACTION contines to progress with lightning speed?

LOGIC and COMMON SENSE seem to be in short supply, eh?

ajasfolks2

Quote

Quote"Accidents are never planned. Individuals with an allergy to peanuts or tree nuts who have been prescribed epinephrine, available as EpiPen(R) or AnaKit(R), should be sure to carry it with them at all times."

~Anne Munoz-Furlong, FAAN, 1999


http://www.pslgroup.com/dg/f4092.htm

pumpkin

Quote
This document is Virginia Law.  I understand that your ds will self carry and that we are talking about a back up dose, but someone work through this with me. Can we read into this, that someone should be carrying a second dose for him?

Ajas, who would inject the second dose? I'm assuming your son wouldn't
so if it's his teacher then why can't she carry it? What's the reasoning behind the locked dose?

§ 22.1-274.2. Possession and self-administration of inhaled asthma medications and auto-injectable epinephrine by certain students.

A. Effective on July 1, 2000, local school boards shall develop and implement policies permitting a student with a diagnosis of asthma or anaphylaxis, or both, to possess and self-administer inhaled asthma medications or auto-injectable epinephrine, or both, as the case may be, during the school day, at school-sponsored activities, or while on a school bus or other school property. Such policies shall include, but not be limited to, provisions for:

1. Written consent of the parent, as defined in § 22.1-1, of a student with a diagnosis of asthma or anaphylaxis, or both, that the student may self-administer inhaled asthma medications or auto-injectable epinephrine, or both, as the case may be.

2. Written notice from the student's primary care provider or medical specialist, or a licensed physician or licensed nurse practitioner that (i) identifies the student; (ii) states that the student has a diagnosis of asthma or anaphylaxis, or both, and has approval to self-administer inhaled asthma medications or auto-injectable epinephrine, or both, as the case may be, that have been prescribed or authorized for the student; (iii) specifies the name and dosage of the medication, the frequency in which it is to be administered and certain circumstances which may warrant the use of inhaled asthma medications or auto-injectable epinephrine, such as before exercising or engaging in physical activity to prevent the onset of asthma symptoms or to alleviate asthma symptoms after the onset of an asthma episode; and (iv) attests to the student's demonstrated ability to safely and effectively self-administer inhaled asthma medications or auto-injectable epinephrine, or both, as the case may be.

3. Development of an individualized health care plan, including emergency procedures for any life-threatening conditions.

4. Consultation with the student's parent before any limitations or restrictions are imposed upon a student's possession and self-administration of inhaled asthma medications and auto-injectable epinephrine, and before the permission to possess and self-administer inhaled asthma medications and auto-injectable epinephrine at any point during the school year is revoked.

5. Self-administration of inhaled asthma medications and auto-injectable epinephrine to be consistent with the purposes of the Virginia School Health Guidelines and the Guidelines for Specialized Health Care Procedure Manuals, which are jointly issued by the Department of Education and the Department of Health.

6. Disclosure or dissemination of information pertaining to the health condition of a student to school board employees to comply with §§ 22.1-287 and 22.1-289 and the federal Family Education Rights and Privacy Act of 1974, as amended, 20 U.S.C. § 1232g, which govern the disclosure and dissemination of information contained in student scholastic records.

B. The permission granted a student with a diagnosis of asthma or anaphylaxis, or both, to possess and self-administer inhaled asthma medications or auto-injectable epinephrine, or both, shall be effective for one school year. Permission to possess and self-administer such medications shall be renewed annually. For the purposes of this section, "one school year" means 365 calendar days.

(2000, c. 871; 2005, c. 785.)

pumpkin

Quote
I just don't get it. Legislators understood that the right to self carry is necessary, I'll bet they never thought that an administration would object to a back up dose being in close proximity to a student.

Maybe a call to your representative and a request for a letter to your school district is in order?

So Wait~ if your school is locking kids epi pens, they are breaking Virginia State Law. Right??

ajasfolks2

Quote
It's the county health department that has this form which seems to give some latitude to the public health nurse and admin at this district's schools to lock the epipens. The county's form, adopted by my school district, is not exactly in line with that Virginia code, IMO. I suspect the county health dept which overseas these PHNs has incorrectly set this policy . . . . and NOBODY has ever challenged.

Pumpkin -- there is little "reasoning" entering into the decision so far as *one* of the players -- she deals only in illogic and hysteria. Additionally, there is insistence by this same person that the law says they can/must be locked up . . . .

I'm just working to build the case against this practice -- NOT just for us but for ALL the children affected by this wrong-headed policy.

NO CHILD'S EPI should be locked AND the Epis should be co-located with the children for whom they are prescribed.

Period.

ajasfolks2

Quote
Pg 83 & 85 apply -- note the "within two minutes of onset" wording as to use of epinephrine. 

EVEN THAT IS SIMPLY TOO LONG!!


http://www.doe.virginia.gov/go/VDOE/Instruction/2007crisis_guide.pdf



The above guide references these for guidance:


http://aappolicy.aappublications.org/cgi/reprint/pediatrics;107/2/435.pdf


and


http://www-prod.pen.k12.va.us/VDOE/Instruction/Health/VSHG-16.pdf

CMdeux

QuoteAs for 'how long is too long'--

I think that two public stories of anaphylaxis death would go a LONG way to demonstrating why any delay-- ANY-- is simply TOO LONG.

Case number one:  Kristine Kastner.  (The first EMT's were on scene within about ten minutes of her ingestion-- any way you look at this timeline, it is terrifying.)
PBS Online Newshour June 8, 1999

Quote
Paramedics showed up eight minutes after the first EMT had arrived, but the girl's heart had stopped. Her family believes those eight minutes cost her life.

The second case was only this past summer.  Also in the Puget Sound area, ironically.   

I'll see if I can dig up the details.


Here it is.

Daniel Sargent.

Stark Reminder of Food Allergy Risks

Quote

Daniel Sargent was at Magnuson Park on Sunday, celebrating a friend's 30th birthday.

About 90 seconds after taking a bite out of a chocolate chip cookie, he collapsed.

By chance, an Everett pulmonologist, a nurse and a medic were attending the party. They administered CPR until aid crews arrived.

Sargent, 30, of Everett, was rushed to Harborview Medical Center. Medical staff battled for two days to help him overcome the complications of anaphylactic shock, an extreme allergic reaction that blocked his breathing and deprived his brain of oxygen.

Doctors tried cooling his body for 24 hours and heavily sedating him, in the hope that his body could rest and recover.

Monday afternoon, his blood pressure skyrocketed and his heart rate dropped. Tuesday evening, two neurologists pronounced Sargent brain dead.

All this, his family said, from taking one bite out of a homemade chocolate chip cookie, one that had just enough peanut butter to trigger his extreme allergic reaction.

Daniel Sargent also had the best possible medical care available-- within MINUTEs.  But it wasn't soon enough.  He was not carrying epinephrine with him at the time.

The important features to note in BOTH cases are (IMO):


1.  Even with all possible vigilance, an accident can happen. 

2.  Both reactions were recognized IMMEDIATELY.  In a school setting-- on a playground, in a classroom with a substitute teacher, tack on additional minutes before anyone knows what is happening.

3.  No amount of basic first aid is a substitute for IMMEDIATE epinephrine. 


(The most distressing thing about both cases to us as family members is that even instantaneous epi might not have been enough given the apparent rapidity of these two reactions...  but then again, this is quite a cogent argument for not relying on an emergency action plan in the absence of other avoidance strategies.)

ajasfolks2

Quote
Crossposting this here as it may have applicability.

http://nursingald.com/newsletter_thumbs.php

guest

Quote
From Guidelines for Managing Life-Threatening Food Allergies in Connecticut Schools.
http://www.sde.ct.gov/sde/lib/sde/PDF/deps/student/health/Food_Allergies.pdf


a.    Storage of emergency medications
Connecticut regulations, Section 10-212a-5 (b), require that all medications, except those
approved for self administration, "shall be kept in a locked container, cabinet or closet used
exclusively for the storage of medication." Sometimes school districts interpret this to mean
that all medications must be locked up at all times.   ]This interpretation is at odds with the
evidence that rapid access to and administration of emergency drugs is critical to saving lives
in episodes of anaphylaxis and other medical emergencies. It is also at odds with the general
practice of most school nurses who unlock their cabinets with non-controlled medications
while they or other staff members trained in medication administration are supervising the
health office.[/b][/b] These factors, and Connecticut regulations Section 10-212a-5 (c), which limits
access to all stored medications "to persons authorized to administer medications," support
the interpretation that medications must be securely locked whenever they are not under the
direct supervision of a nurse or other authorized and trained staff member (for example, a
classroom teacher) in preparation for potential use. To promote rapid, life-saving steps in an
emergency, therefore, emergency medications should not be locked during the school day.
While they must not be accessible to any student or unauthorized staff member, they should
be kept in a safe, accessible and reasonably secure location that can be properly supervised
by a nurse or other authorized and trained staff member.
As a matter of safe practice, it is generally reasonable for schools to require that parents
supply an extra set of emergency medications for availability during extra-curricular activities
that occur outside the regular school day. This allows the "school-day" medications to be
properly stored and locked after regular school hours to ensure that they will be available –
without fail – the next morning when the student arrives at school. Plans for sharing
medications between regular school programs and before- or after-school programs generally
leave more opportunity for unintended error and unexpected events than is safe. In some
instances, families may need assistance from the school district to find financing for a second
set of emergency medications.

YouKnowWho

Quote
Can their be a box, much like a fire extinguisher or alarm that has glass on the outside WITH a hammer?  Would that satisfy the need to have it locked but still be accessible?  (thinking out loud here)

In the nurses office when I was a child would have meant certain death for mine.  I was often in portable classrooms that were not within 60 seconds of the nurses office even if running at full paniced speed.  And then if they had to return to the classroom to bring the pen with them 

It also makes me think of recess/pe when we were at the far end of the school property far away from classrooms, so as not to disturb those children...

Y'all have given me so much food for thought...

Mezzo

Quote
They unlocked ours last week after I provided the joint document produced by FAAN, NASN, NAESP, etc., that states that Epis should not be in locked cabinets. Hallelujah. That makes a huge difference to safety at school.

TabiCat

Quote
I'm fighting this battle too. The childcare licensing code states that all medication must be looked or the Preschool, Daycare, or childcare center will brie in violation. Headstart was willing to fight and took a hit because teachers were carrying the pen in their apron pocket.

So far we have been able to convince them that the Epi Ready is "locked." So they are everywhere they even mounted one on the fence in the playground one of the dads built a little shade for it to keep the sun off it.

ajasfolks2

QuoteBump & adding link to CMdeux's thread in MAIN

References needed-- under-recognition of ana.

http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=9463

guest "alliedhealth"

Quote
http://www.aaaai.org/media/resources/academy_statements/position_statements/ps34.asp

In case no one had linked to it- here is AAAAI's position statement that is very good re schools and under treatment strategies states "epipens should be readily available and not in locked drawers or cabinets"

ajasfolks2

QuoteLinking to the NURSE thread here.

http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=6756&latest=1
If BEST PRACTICES (per AAAAI and others) includes that the Epipen should be co-located with the allergic individual, then the SCHOOL NURSE should be advocating for this as well. . . .


_{(in other words, not advocating for the lock up in clinic 2 flights of stairs away)}

TwoDDs (2009)

Quote
Thanks for the bump. Very helpful information here. I'll update if there's an update to be had. . . .
~ ~ ~
I was able to locate my state regulation requiring all medications be locked up and figure out who was responsible for same. I sent off a request for change using some of the docs here.

More Follow Ons

ajasfolks2

Quote
I don't want to goober up this thread with our own personal situation -- but FWIW I think I had better get more details in here. Our son is currently authorized to self-carry his pair of Epis.  (The ONLY LTFA kid in the school to have this privilege.)  The doctor ordered a 2nd set to be kept at school according to the county's Epi form.  The 2nd set is to be used in event one of first set doesn't work or is used improperly and child might need back up (15 minutes pass and no EMS . . . . nothing to do with symptoms, recall NO symptom recognition allowed here . . . ).  ALSO some of our EMS vehicles do NOT carry Epinephrine, so the doctor advised us to ALWAYS carry back up in ambulance in event we need to SELF ADMINISTER more in the ambulance if too much time in transit -- obviously we'd be using more Epi in that event ONLY if symptoms warranted as NOW we'd not be with the we-cannot-recognize-symptoms-school-staff any longer.

Important to note that the Epipen form does NOT state meds must be locked. 

http://www.fcps.edu/DIT/forms/se64.pdf

Form states the following & doc may check 1 option (OK, our doc checked both and put "for backup" in the blank on 2nd option.):

Quote
__  The student is to carry an EpiPen or Twinject during school hours with principal's knowledge.  The student can use the EpiPen or Twinject properly in an emergency.  One additional dose, to be used as a backup, should be kept in clinic or other school location.

__  The EpiPen or Twinject will be kept in the school clinic or other school-approved location __________________________ .

In our instance, the lock seems to be the doing of the PHN (+ former admin) who was in place at this school prior to the principal's arrival.  The locked file cabinet that is being used appears to have been part of the scheme of things for some time now.  (PHN in conjuction with prior principal?  Maybe also involves policy of the PHN's supervisor at the county health dept.  Just guessing.)

Given that our son has NEVER received an Epipen injection (though he should have previously) AND given that he has NEVER actually administered EpiPen to himself, there is all sorts of room for error on this, despite his excellent training and understanding of when to use.  Mind you, he IS trained to recognize symptoms and when to administer according to BEST PRACTICES and the USUAL doctor's orders . . . . which absolutely does not necessarily follow the epi form set up here.

Worthy of note is that the form allows for ONE Epipen or Twinject.  Now, 1 Epipen means a single dose pen.  1 Twinject means a 2-dose apparatus.  The public health department and its committee didn't even catch that LITTLE detail, now, did they?!!  HELLOOOOO?!  (DS's pack has pair of Epis and the BACKUP in the locked cabinet is a PAIR of Epis.)

I have to wonder how many EpiPen-prescribing docs here realize that the Epis are being kept LOCKED and AWAY from the LTFA children?!?!?!

~ ~ ~ ~


Back to this topic in a general sense -- my husband and I will not rest until we have the Epipens UNLOCKED and co-located for ALL the LTFA children in this school . . . and this county . . .


AND


Until there is LEGAL MANDATE for ALL schools/childcare nationwide to have the Epipens UNLOCKED and co-located with the LTFA person.

Hence this thread. 

More follow ons.


Mfamom

Quote
To me, this is similar to them not "locking" fire extinguishers. Yes, you have to break the glass in some cases, but imagine if someone wanted to lock them in a cabinet somewhere in the school building?
They place them in strategic places in event of fire. they are secure, but accessable.
I'm sure misuse of a fire extingusher would result in harm far more than misuse of epi pen.

jw

Quote
The New Jersey document is great. The only bad thing is the non-allowance of delegation for antihistamines. I hope you have more in-school nurses than we do.

unknown

Quote
This AAAAI doc says Epi's should NOT be locked

http://www.aaaai.org/media/resources/academy_statements/position_statements/ps34.asp

Here's another one

http://www.foodallergy.org/school/guidelines/SchoolGuidelines.pdf

& another

http://www.doe.mass.edu/cnp/allergy.pdf

mfamom

Quote

QuoteThe New Jersey document is great.  The only bad thing is the non-allowance of delegation for antihistamines.  I hope you have more in-school nurses than we do.

Yes, it has been a thorn in my side.  But, it is at least better because before this new law, the old law basically said that if you have an antihistimine order, YOU CANNOT HAVE A DELEGATE.  I always resisted having no benadryl order b/c DS used to be very sensitive skin wise and I didn't want him getting an epi pen because he was having hives from env.
Now, you can have a delegate, but that person cannot give benadryl.  I am fine with that.
So, since kindergarden, if the nurse was absent, DS didn't go to school.  If we had early/after school activity, and the nurse wasn't there, I sat there. 

They are definitely coming out of the dark ages with the new law. 

ajasfolks2

Quote from: 13 post_id=122007 date=1222280288I would appreciate any thoughts/comments anyone here might have (maybe used before with schools?)  in dealing with school staff (admin or nurse) who insists the Epipens must be locked up to protect the other children.

(Yes, I have my own thoughts, but the more great wording we get here the better for all of us.)

There's a few of you here who might have eaten alive a certain staff member at 504 meeting who insisted on Epipens being locked and it being a felony if another child gets hold of it         and other completely useless, incorrect or non sequitur comments . . .  DO NOT QUOTE

Momcat

Quote
that's preposterous! Is that person thinking that EpiPens are a controlled substance?

PeanutMilitia

QuoteYes, we too were intimidated with the threats of a felony. Look into Nebraska right to carry law--it deals with inhalers. I have to go to school right now or I would do leg work for you.

One of the points the anti-carry people were making is that inhaler spacers used for children are also used for huffing and therefore should not be allowed on school grounds regardless of reason (like saving my kids life). We pointed out that intentionally keeping medication away from a person in a lifethreatening situation is also grounds for felony conviction (there are MANY cases to point). Intentionally locking insulin away from a diabetic I am 90% sure is what undid the vanderbuilt murder case. I may have the famous name wrong. But the idea is the same--they know know your child needs his Epi. If they keep it from him they are neglegent.

Guest

Quote

Quotethat's preposterous! Is that person thinking that EpiPens are a controlled substance?

thinking? 

what made you think that person could THINK?!   

PeanutMilitia

Quote
OK, now that my mad dash to school is over here are my thoughts--keeping in mind I am just a parent like you, this is what I have come up with.

They have you on the defensive--it is time to switch places.

If they insist it isn't safe;
regardless of what other schools do, regardless of other state's law,

It seems to me     if they are correct and they understand your child needs an Epi quickly in an emergency they are suggesting a 1:1 ratio nurse (if they insist a qualified person carry the Epi) or nurse's aid to accompany him.  I would try to get in writing that they do not want him to carry his own Epi.  Then, very politely ask when the nurse (aid) will start.  Call their bluff.  I think letting a child with a history of self-carry keep a life saving device on his person is more efficent than having to hire a nurse just for his medications. 

I am sure you have thought of the fact you son has a successful history of self-carry--has he ever had an accident with his medications?  Do you have a teacher from the other district that would email or write you to that effect?

Not that we like to think about these things, but I would try to get their statement that they do not want him to self carry in writting in the event he does need the Epi and does not have it on him.  Even if it is delayed minutes they are affecting his recovery time.

Sorry the new school is putting you through the wringer.  I will PM you another thought we used.

Mfamom

Quote
I fought this early on, but our State Law did say that ALL medications must be stored in a locked cabinet. I didn't have a 504 back then and really couldn't argue the point anymore.

I was okay with it for many years because our school is very small and DS was in close proximity to the nurse. There were keys to the cabinet in the main office, and in the principals possession as well as spare keys to the nurse's office.

We also didn't have a delegate, so even if the stupid thing would have been in the room, noone would have given it to him unless he self administered.

Are they saying also that self carry is out of the question as well?

Mfamom

Quote
How likely is it for a child to just saunter into the nurse's office and start looking for meds? Seriously, I think that scenario is really remote.

CMdeux

Quote
...or, for that matter, into any classroom??  I mean, Hel-lo??

' ' Supervision?' '

<muttering>  Someone needs to give these MORONS a *%&#$ing reality check.  About their liability.  After all, during a cardiovascular compromise, seconds are brain cells.  DUH.  If they think liability is high for a kid misusing an epipen.... maybe they prefer what happens if I win a lawsuit for them to support my now-vegetative child-- for life.   

Guest

Quote
MN Law allows self-carry or "immediate access to to nonsyringe injectors of epinephrine in close
proximity to the student at all times during the instructional day"

http://https://www.revisor.leg.state.mn.us/bin/getpub.php?pubtype=STAT_CHAP_SEC&year=current§ion=121A.2205

Follow ons

ajasfolks2

QuoteRelated thread looking for supporting info here in our Main area:

http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=6686

Mfamom

Quote
http://www.state.nj.us/education/students/safety/health/epi.pdf


Secure but unlocked storage of epinephrine in locations easily accessible by the
school nurse and designee(s), to ensure prompt availability in the event of an allergic
emergency at school or at a school-sponsored function (A school-sponsored function
means any activity, event or program occurring on or off school grounds, whether during
or outside of regular school hours, that is organized and/or supported by the school as per
N.J.A.C. 6A:16-1.3);

Here's our new state guideline. Previously, NJ laws stated that ALL medications at school be in a locked cabinet. They finally addressed it here!

ajasfolks2

QuoteI will get back in here during next couple of days, but I wanted the purpose of this thread to be to

UNLOCK THE EPIPENS nationwide!

We need to post here all the supporting documents and quotes from professionals in the medical field as well as other reputable organizations in support of UNLOCKED and CO-LOCATED epinephrine for anaphylactic children in school or daycare.

IS their anything in writing from OCR regarding UNLOCKING these life-saving meds?

So, please post your best sources and links here so we can have this thread as a resource and place of discussion on this single topic!

Thanks!