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If that is the chart the lady provided to go with her comment of raising rates 5X, I wonder if she is reading it wrong and overreacting? Because to go from approx $60 to over $300 would be 5X but that second number doesn't look to be the proposed new licensing fee. It looks to be the proposed new violation fee.
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I agree... Fine away for providers going over ratio! That is one thing I can & will always make sure that I always follow to the letter of the law in Ca regs! It's clear and in black & white...My real concern falls that what if if OTHER Title 22 regs aren't followed .... Many are "grey" areas and open to interpretation!
I have had an LPA come out unannounced in August 2010 and find I was 100% in compliance only to have another one come out 6 months later and actually cite me for not having what "she" says are the appropriate child proof locks to make the items under my bathroom vanity "inaccessible". (They were cosmetics- not cleaning products.) When I told the analyst that those child proof locks had been there for 20+ years and just recently had been approved a few months ago, she said, "Well, Santa Clara Co prefers the use of these other kind now." According to her, this has been the "new reg" for over a year.... So now I'm even more confused, because why are these analysts not all on the same page!
Furthermore, I will gladly change to whatever child proof lock they now prefer, BUT don't cite me for something I had Absolutely no clue about Or that your agency had recently just okayed!!!!!
When I appealed, management stated, that it's not actually in writing, but new providers are told this in orientation! Ok, well that's great for them... What about providers like me, that have been at this for 28 years! It's not in any of the updates at all!
SO....My issue is this- --- if they can't have clear, concise black & white regs for us to follow, what financial burden will this pose if we are cited and monetarily expected to pay fines on things they arbitrarily decide to change on a whim?!?!?
Geez, if you get a ticket by the police, you can at least go to court to have a fair hearing in front of a judge! Idk...maybe I am jaded, because I have been at this a long time and had the unfortunate experience of dealing with a few "natzi" like analysts that do NOT do a just job.
Maybe I am the only one with concerns on this.... I just thought it was alarming that the State is pursuing a financial gain with providers being at a disadvantage over clear cut regs here in Ca. :confused:Comment
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Exactly. That's how I'm reading it as well. Maybe after 44yrs the business is getting to her. I don't claim to know it all but this chart seems pretty clear cut. They raised the annual fees by a little and they're increasing fines for those who get major violations. It's just crazy to think they'd raise it 5x in one year after years of it being so low. I could even see doubling it, but 5x? That's crazy!Comment
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I actually just googled it and think you are correct. It states in the bill 10% annual fee and the violation rate being 5x that amount.
I had merely copy and pasted what she had written.
Title 22 violations can be extensive, so providers need to be aware if this bill does get passed! So many things in Title 22 are open to each individual/counties interpretation and we are not as fortunate as other states that have clear consistent regulations laid out in black and white to follow!
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I actually just googled it and think you are correct. It states in the bill 10% annual fee and the violation rate being 5x that amount.
I had merely copy and pasted what she had written.
Title 22 violations can be extensive, so providers need to be aware if this bill does get passed! So many things in Title 22 are open to each individual/counties interpretation and we are not as fortunate as other states that have clear consistent regulations laid out in black and white to follow!
Type A violations are clarified here in this PDF file from 7yrs ago. A type A violation has to be pretty significant. Leaving meds, cleaners, etc. accessible to kids and such. Non working smoke detectors or extinguishers. Of course "immediate danger" is something one analyst may view differently than another but from what I've heard a type A is pretty severe. A local provider had a few type A's, cleaners and meds accessible from what the report said. The rest of her violations were clerical stuff which is type B.Comment
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Yes, and like I stated, I had a type A, because of "toiletries" under my bathroom vanity. (I had a facial cleansing cream that says "keep out of reach of children".) Licensing approved the child proof lock for 20 + years.... Now boom it's NOT ok and I get cited! This is my point! Inaccessible is a variable.Comment
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It was a "child proof lock" that had been approved for almost as long as I've been licensed. I'd had numerous analysts over the years come out and it was totally fine. In Aug. 2010 it was STILL ok... First time I heard I needed "tot locks" was January 2011. Management said it isn't required state wide! I was told many counties still are not in agreement on the use of tot locks exclusively. It's open to each county on what they wish to require!
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Because these things tend to spread state to state, could you tell me what is meant by "tot lock" and "child proof lock"? Also "two part lock"?It was a "child proof lock" that had been approved for almost as long as I've been licensed. I'd had numerous analysts over the years come out and it was totally fine. In Aug. 2010 it was STILL ok... First time I heard I needed "tot locks" was January 2011. Management said it isn't required state wide! I was told many counties still are not in agreement on the use of tot locks exclusively. It's open to each county on what they wish to require!
I use the magnetic locks with a magnet "key" for keeping diapers and diapering products inaccessible, because the old plastic childproofers (that you pushed on with a finger behind the door) were no longer acceptable here.
Can't imagine having to keep diaper stuff under an actual lock and key:confused:Comment
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so in my case I would not pass the lock test. I rent so I can NOT drill any holes in any of my cabinets. I only have the only style finger push down locks, but my DC bathroom is 100% DC so the only thing under the sink is diapers. Nothing else.
In my kitchen there are only pots and pans, and plastic dishes, nothing else, so I have no locks. I have a recycle bin under my sink , no chemical at all.
So with that being said, wonder if I would still passComment
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The "tot lock" is just the brand for magnetic locks they wanted used. Basically a two part locking device like you described. They hadn't invented them yet when I first started! All they had were just the plastic child proof devices that you latched on the knobs had to squeeze and move, so you could open the cupboard.
This is a much more secure way to keep a child out & I had no issue installing it or the fact that they now preferred this method of making something "inaccessible" with this new device... Just don't cite me with a Title 22 violation when I'm using what has been the approved method of child proofing a vanity for over 20 years and had just been okayed 6 months prior!!!! That's my complaint!
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Daycare, you'd be fine as long as there's nothing in there that needs to inaccessible! For years, this was my own kids bathroom, so they had tooth paste etc in the cabinet. No meds were ever in there (it was a kids bathroom!)
When she saw I had the other old style latch, it was like she'd hit a jackpot! She pulled everything out...it was mostly my daughters hair products and some face soaps. She listed everything like I had super toxic things "unlocked". I'm just glad I didn't get a fine on top of it! I think that's where they are headed.
She also wanted me to put one on the cabinet under my kitchen sink too. I have never stored detergents or cleaning products under there...they've always been kept outside in garage or in the cabinet above my refrigerator. All I have under there are my 2 garbage cans, but she thought it was good to do it, so I could store things there if I ever wanted to.
So, I had my dh install one and it was a HUGE pain! I never realized how many times a day, I needed throw garbage or recycling away!!!! I had him take it off after a month! I'd had no problem for 20+ years storing things above my fridge and it worked for me! Locking up my trash cans though was a major inconvenience though!
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