In the main, this is a well thought out amalgamation of the birth-to-three framework and the early years curriculum guidance. The principles are everything we would expect and clearly set out what is needed for children's emotional support when they're away from home for what are often long periods (50-plus hours a week for many babies and toddlers). Terms such as "attachment" and "key person" are clearly defined. All in all, an excellent piece of work.
So why am I concerned - no, not concerned, absolutely furious? Well, it's mainly on account of page 120. It's the bit about ratios and bringing the private and voluntary sector into line with schools. In a nutshell, if a private nursery employs a teacher - any teacher, or an "early years professional" or anyone with a relevant level 6 qualification alongside at least one person qualified to level 3 - then all other staff working with three to five-year-olds will be on a 1:13 ratio, as in nursery schools. Not worried yet? You should be. Unless this page is rewritten and tightened up until it creaks with the strain, we will be putting quality to the bottom of the agenda and sacrificing our children to baby farms.
Potentially, we could have a secondary-trained history teacher who has not taught for 10 years working alongside a 17-year-old with an NVQ level 2 with 26 children between them. In large nurseries, working on the 1:13 ratio there could be a teacher two floors up from level 2 staff. Currently the ratio is 1:8, which will remain where no graduate is employed, and before 8am and after 4pm in all private and voluntary settings.
Children are only in schools for around five to six hours a day. For many in private day care the figure is double that. The new document lays out carefully the case for children's needs for attachment and a key person with whom they can form this bond, but then undermines it at a stroke by removing staff. One to eight is a minimum standard according to the Children Act; it is not a generous staffing arrangement which can be pruned with impunity. On a 1:13 ratio there will be little opportunity for cuddles and individual attention.
Private day care is run for profit in most cases. Schools are not. This has a major effect on quality. Also, schools cannot work with one teacher and many nursery nurses. The new early years foundation stage document does not make this distinction for day care.
It doesn't stop there. We were promised that the national standards for day care would be reviewed. We were told at the conference that the national standards printed at the back of the document are the new version. Please let this be a mistake. It still says quite clearly that children should have access to outdoor play - where possible. Also that there should be adequate natural light - where possible. While I do not know of any maintained schools where children cannot see out of a window, I could take you to several private nurseries where this is the case. I do not know of any schools without a playground, but I know of a private nursery without one and I expect it isn't an isolated case.
When the issue of early years settings without outdoor play came up at the conference, it was suggested that no one would want to close down the local playgroup running from a church hall. No, we all agreed, children only attend playgroup for around two and a half hours a day, but the standards should be much higher in full care; the children virtually live there and so need much more than those in sessional care. Surely it's not too much to ask for separate standards for different types of care.
Worst-case scenario: 26 children in a room with two young staff, both with NVQ level 2 qualifications. Two skylight windows and no outdoor play on offer. This would be legal under the new legislation. This is a consultation document. Take the time to respond.
Helen Sanderson is an early years consultant. She writes under a pseudonym