Every New Child Needs Their Individual Plan Before Day One — Not After. Here's What Ontario Law Actually Requires.

Picture the week you're about to have. Six, eight, maybe fifteen new children starting within days of each other. Registration forms arriving faster than you can read them. Somewhere in that stack is a form that says a child has a peanut allergy severe enough to require an EpiPen.

Here's the question that matters: is that child's individual plan supposed to be ready by the end of their first week, so your team has time to get organized? Or is it supposed to already exist, signed off, communicated to every educator who might be in that room — including a substitute — before that child's shoes come off on day one?

It's the second one. That's not a best-practice recommendation. It's Ontario law, and it's worth being precise about it during exactly the week most centres are least organized to meet it.

What the Law Actually Requires

Definition: Section 39 of Ontario Regulation 137/15 (under the Child Care and Early Years Act, 2014) requires every licensee to maintain an anaphylactic policy for each child care centre it operates. The policy must include a strategy to reduce the risk of exposure to anaphylactic causative agents, a communication plan for disseminating information about life-threatening allergies, an individual plan for each child with an anaphylactic allergy — developed with input from the child's parent and physician — and training for staff on emergency procedures. There are no exceptions to this requirement, even for centres with no currently enrolled child who has an anaphylactic allergy.

This traces back to Sabrina's Law, passed in Ontario in 2005 and named for Sabrina Shannon, a teenager who died from an anaphylactic reaction during her first year of high school. The law requires every school board — and, through the CCEYA framework, every licensed child care centre — to have a real, working anaphylaxis policy, not a document that exists to satisfy an inspector.

Four things the policy has to actually do:

Reduce exposure risk. Concrete steps to limit contact with known allergens in the room, at snack and mealtimes, and during shared activities.

Communicate the information. Not just file it — make sure everyone who might be responsible for that child on a given day actually knows.

Build the individual plan. With input from the child's parent and physician, covering emergency procedures specific to that child.

Train staff. On what to actually do if a reaction happens — not in the abstract, but for the specific children currently in the room.

The Part Most Centres Miss: "Before," Not "During Onboarding"

The individual plan isn't supposed to be a first-week task. The expected sequence is: before a child's first day of enrollment, the parent or guardian meets with the director to provide input on the individual plan and emergency procedures. The plan itself needs to be developed — with parent and physician input — ahead of that first day, not built up gradually as the centre "gets to know" the child.

This is where a fall intake surge creates real risk. When new children are starting one or two at a time, spread across weeks, a centre has natural breathing room to run this process properly for each one. When six or ten start within the same week or two — which is exactly what a September intake looks like — that breathing room disappears. The paperwork volume doesn't change what the law requires. It just makes it much easier to fall behind on it without anyone deciding to.

And this isn't limited to anaphylaxis specifically. Ontario's licensing framework requires individualized plans more broadly for any child with a medical condition requiring support — a child with diabetes who needs blood sugar monitoring, for example. Those plans are also developed with the parent and any relevant health professional, and they cover emergency procedures, day-to-day supports, and what happens during an evacuation or an off-site field trip. Medication authorization — including "as needed" medications like an inhaler — requires its own written, physician-backed authorization on file before that medication can be administered at all.

The Communication Plan Is Where It Actually Breaks

Here's the failure mode that matters most in practice: the plan exists, correctly filled out, in a binder or a folder — and the substitute educator covering a sick staff member's room that day has never seen it.

Section 39 doesn't just require an individual plan. It requires a communication plan — the mechanism by which that life-threatening information actually reaches whoever is responsible for that child, on any given day, including a day nobody planned for. A plan that exists only in a filing system a regular educator knows to check isn't a communication plan. It's a document.

This is the gap that shows up most often during exactly the period a centre is absorbing the most new children at once: the information exists, technically, but it hasn't propagated to everyone who needs it before someone needs it.

What This Should Actually Look Like Before Your Next Child Starts

A few concrete markers worth checking against your own process, especially right now:

The parent meeting happens before day one, not during week one. If a family's start date is approaching and that conversation hasn't happened yet, that's the thing to fix this week — not something to schedule once they've already started.

The plan has physician input, not just a parent's description. A form filled out by a parent from memory is not the same as a plan built with the child's physician, and Section 39 is specific about that requirement.

Every educator who might cover that room knows — not just the lead educator. That includes anyone doing a shift swap, a relief booking, or covering an absence. If the answer to "would today's substitute know" is uncertain, the communication plan isn't actually working yet.

The information is visible at the point of need, not filed somewhere that requires someone to remember to check it during snack time or a birthday celebration brought in from outside.

Annual review is actually happening, not assumed. Individual plans are meant to be revised yearly and adjusted any time a parent reports a change — a new allergy, a changed dosage, a resolved condition.

Where Root Skills Fits — and Where It Doesn't

To be precise about this, because precision is the entire point of this post: Root Skills does not create or file the legally required individual plan itself. That plan has to be built with the parent and, where relevant, the child's physician — it's a specific legal document, and it stays exactly where it should: with your director and your families.

What Root Skills does is remove the gap between "the information exists on a form" and "every educator can see it immediately." When a registration form comes in, Import from Forms drafts the child's full profile the same day — allergies, dietary restrictions, and parent notes included, not just name and schedule. From that point on, anaphylactic alerts surface directly on the child's card, visible to whoever opens that profile, including someone covering the room for the first time. It's the difference between allergy information living in a binder that has to be remembered, and allergy information showing up automatically wherever an educator is already looking.

During a week where you're onboarding a dozen new children at once, that's the part that actually breaks down first — not the paperwork itself, but getting it in front of the right person at the right moment.

Frequently Asked Questions

Does an anaphylactic policy need to exist even if no enrolled child currently has an allergy? Yes. Section 39 of O. Reg 137/15 requires every licensed centre to maintain an anaphylactic policy — either its own or the ministry's standard policy — regardless of current enrollment. There are no exceptions.

When does a child's individual anaphylactic plan need to be ready? Before their first day of enrollment. The expected process has the parent meeting with the director beforehand to provide input on the plan and emergency procedures — it isn't meant to be assembled during the child's first week.

Who has to be involved in building the individual plan? The child's parent and, per Section 39, the child's physician for the anaphylactic emergency procedures specifically. A parent-only description isn't sufficient on its own.

Does this apply to conditions other than anaphylaxis? Yes. Ontario's licensing framework also requires individualized plans for other medical conditions needing support in care — for example, a child with diabetes requiring blood sugar monitoring — developed with the parent and any relevant health professional.

Does Root Skills manage our anaphylactic policy or individual plans for us? No — those remain your director's responsibility, built directly with families and, where required, physicians. Root Skills' role is narrower and practical: Import from Forms captures allergy and medical information from registration paperwork the same day it arrives, and anaphylactic alerts surface on every child's profile so any educator in the room — including a substitute — sees it immediately, rather than that information sitting in a binder.

What's the risk if a substitute educator doesn't know about a child's allergy? This is precisely what the communication-plan requirement in Section 39 exists to prevent. A plan that only the regular educator knows to check doesn't meet the intent of the requirement — the information needs to reach whoever is actually responsible for the child that day.

The Bottom Line

A busy fall intake doesn't change what Section 39 and Sabrina's Law require — it just makes it easier to fall behind without noticing. The plan has to exist before the first day, not the first week. The communication has to reach every educator who might be in that room, not just the one who's usually there. And when six or ten new starts land in the same week, that's exactly when the gap between "the form was filled out" and "everyone in the room actually knows" tends to open up.

Root Skills is built to close that specific gap — registration paperwork becomes a full, alert-ready child profile the same day it arrives, visible to whoever needs it, whenever they need it. Free 14-day trial, no credit card required. Starting at $129/month.

Start your free trial at rootskills.ca

Sources: Government of Ontario, Ontario Regulation 137/15 under the Child Care and Early Years Act, 2014, Section 39; Government of Ontario, Child Care Centre Licensing Manual, Part 5 — Health and Medical Supervision; Legislative Assembly of Ontario, Bill 3, Sabrina's Law, 2005; sample anaphylactic policy documents published by licensed Ontario centres (Rippleton Roadsters Child Care Program; PLASP) for illustrative confirmation of standard practice. This post summarizes publicly available regulatory requirements as of July 2026 and is not legal advice — confirm your centre's specific policy and documentation against the current regulation text and your licensing consultant.