Opinion: The impression from the carpark is very inviting.

The area is well fenced but barred so there is easy visibility of loved ones.

Inside, the spaces are welcoming and clean and staff are friendly and clearly comfortable. I am greeted by ‘Kim’. She has worked here for three years, and “just loves” her job.

Spaces are divided and have ratios of two adults per play area. There is a wide range of resources, proudly displayed ‘enrichment experiences’; there is a large area for gross motor (running and climbing). Adult interaction is constant and the language is encouraging and varied. Affection and comfort is given out whenever it is needed.

Day trips are common: a van is fitted out to take passengers to a range of parks, forest and even aquatic experiences.

There is ‘quiet time’ in the afternoon. “All of them need a time to just be calm and chill out. It isn’t good for them to be constantly stimulated. It isn’t good for anyone.”

Photos around the space and online show how much fun and learning is happening each day. The groups are often varied as some are only here a day or two a week, but the staff know which friendships are solid and which are developing.

I ask, “How do you deal with aggression or anxiety?”

“There are different types of aggression so we assess that first and take away triggers. If a newcomer is anxious, we have a separate space where they hang out with one of our staff for as long as they need it. If they don’t settle after a few days we suggest to the parents that this might not be the right environment for them.”

Wouldn’t it be great if I was describing a well-run early childhood education centre.

No, this is the local doggy day care.

How do the regulations differ between doggy day cares and early childhood education centre (ECEs)?

Anyone keeping animals must comply with regulations under the Welfare Act, which stipulates minimums for housing conditions, feeding, vaccinations – and for dogs, behaviour training. There is a ‘body condition’ score that alerts owners and carers to the dog being under- or overweight and therefore prone to disease

Ventilation and numbers of dogs in spaces must be sufficient to remove odours and prevent the spread of infectious diseases.

“Exercise is extremely important for both physical and mental health, particularly where dogs are confined for prolonged periods, and also helps to meet dogs’ social needs. Insufficient exercise can contribute to the development of behaviour problems. Dogs must receive daily exercise sufficient to maintain their health and wellbeing.”

Non-compliance with these regulations can result in fines, having the animals removed and even jail.

In addition, the SPCA has put out a set of voluntary regulations for doggy day care, and is committed to reviewing them every three years. These recommendations include ratios of 1:15, cameras, a maximum number of dogs, clearly stated and never exceeded.

“Lighting, whether natural or artificial, should be sufficient to allow effective observations of animals (lit to at least 50 lux at animal eye level, estimated by ensuring light is bright enough to read a newspaper held at arm’s length).

“Noise levels must not be excessive. Noise is considered excessive if it exceeds 85 decibels averaged over eight hours (equivalent to city traffic inside a car) or a peak noise level over 140 decibels (equivalent to a jet engine at 30m). If noise becomes excessive, steps must be taken to reduce noise through animal training and modification of the physical or acoustic environment.”

What are the comparable regulations in ECE?

First, key regulations for ECE governing ratios and group sizes have not been reviewed for 30 years. The Regulations Select Committee noted in 2021 that regulations governing ratios and group sizes had not been reviewed since the 1990s. RNZ reported in 2021 the committee’s request that this work be actioned ahead of the Ministry of Education plan of 2023, but the ministry refused. Both Labour and the current coalition have not addressed these issues at all.

We have heard from employers that the regulatory requirements in ECE are onerous and ridiculous. The temperature required for refrigerated food is monitored but the nutritional value of  the food served is not. The temperature of a sleep space is monitored, but the number of children, space between cots, ventilation and noise, the safety of teachers, are not. The reduction in play space for non-sleeping children when a sleep area is walled off, does not enter the consciousness of the monitoring bodies.

The number of children in a space is limited only by the space – 2.5sqm per child, including furniture and teachers (this is near the bottom for OECD countries). In baby rooms where there are more adults per child, this is just untenable. Many teachers have reported to me, and I have experienced myself, the lack of space, tripping over toys while carrying infants; anxious babies who feel overcrowded.

In rooms for older children, the space is too often not enough for children to play comfortably or be supervised by adults, and then further reduced when sleep spaces are blocked off, or when the weather does not allow for outside play. They are horribly overcrowded, noisy and exhausting spaces for both teachers and children.

Ratios for adults to children, on paper, are 1:5 for those under two years old and 1:10 between the ages of two and six, where there are more than seven children. There is no upper limit. Humans were not designed to have ‘litters’. It is impossible for one person to attend to the many physical and emotional needs of five infants and toddlers, every day, for weeks and months, with new ones coming in as older ones move out. Fifty children in a room with five adults cannot receive enough crucial adult interaction for emotional or language development.

The Education Ministry has told us repeatedly, over many years, that teachers leaving a room for even a short time must be covered to maintain 1:10 ratios for older children. However, this does not apply to teachers who are in sleep rooms (for maybe an hour or more settling children) or changing nappies (one teacher changing 100 nappies is there all day). This leaves other teachers now down one or two teachers to supervise and care for more than 20 or 30 children.

There is often no ‘settling-in period’ even for infants. The best centres allow children all the time they need to form relationships with staff and to feel safe. Others are taken immediately, with no settling period, and left to cry for hours and even days on end.

There is no standard or regulation for nutrition in ECE. “Food is served at appropriate times to meet the nutritional needs of each child while they are attending.”

There is no need for anyone serving food to have any qualification in paediatric nutrition.

When it comes to exercise, there are centres with no space for children to run at all. The regulations require 5sqm per child, but due to poor centre design, an excess of equipment and just too many children, there may be no running space. Young children, as soon as they are able, want to run. It is a primary developmental requirement for muscles and joints, heart and lungs, eye-sight and proprioception, not to mention their emotional needs. Running makes children happy.

As for noise and lighting, there is no regulation. There is no standard and no monitoring.

ECEs account for more outbreaks of infectious diseases than all other institutions combined and have eclipsed private homes as the main site. There are centres that have had repeated infections not reported to public health units as required. Staff, too, are susceptible to these illnesses and have insufficient sick leave or child care. So many staff work when ill because there is no cover. Sick children are brought to daycare because parents have no alternative care arrangements. Infections just keep circulating.

There are also no ECE regulations governing teacher health and wellbeing – no requirement for ergonomic equipment, maximum daily loads, adult furniture, sufficient (or any) staff rooms, or recommendations for pregnant teachers. Teachers Advocacy Group (TAG) research in 2018 showed 44 percent of 700 respondents had incurred injuries in the previous 12-month period, mainly to the lower back but including strains, from lifting and carrying, slipping and falling; head knocks; child-inflicted injuries such as bites, punches and thrown objects; and hearing and voice injuries, for which there is no ACC cover. Injuries are directly related to ratios and group sizes.

Which brings us to the job satisfaction element. Happy adults make happy children. Teachers Advocacy Group’s periodic surveys of intention to leave among ECE teachers have shown high turnover (there is no government data). The latest poll showed up to 90 percent of respondents have considered leaving the sector in the past 12 months. Teachers have increasingly bemoaned the very high workload, lack of quality care for children and poor working conditions over the past 15-20 years.

More and more doggy day cares are certified according to SPCA standards because clients want and recognise the importance of good care for their pets.

Successive governments have shown an aversion to addressing key regulations in ECE. 

Why do our dogs have more regulatory and certified protection than our very youngest children?

Susan Bates is a registered ECE teacher, independent researcher and the founder of Teachers Advocacy Group.

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1 Comment

  1. It is astonishing that the ECE system is so badly regulated yet we’re told that our ECE centres are expensive compared to comparable countries like Australia. Either other countries ECE centres are complete hell-holes or it sounds suspiciously like somebody is creaming a lot of money off the top as its obviously not being spent on staff and facilties. Maybe someone can inform me how the system works here?

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