The demand for play schools is driven by twin factors: a mother’s need to get back to work and a break-down of extended family support to raise children. Play schools or day care centres serve this demand. Any regulation should address the safety of kids while supporting the needs of working moms. Sadly, the draft code by the Tamil Nadu Government fails in both these aspects.
The Draft Regulation released by the Department of School Education includes all institutions that provide “informal education” to children between one-and-a-half and three-and-a-half years. It has been widely established that the period from birth to six years are the years of rapid brain development in children. Therefore, during this stage, children necessarily require stimulation across cognitive, physical and emotional aspects. The Draft, therefore, brings under its purview all early childhood care and education institutions such as crèches, anganwadis and day care centres.
The Draft proceeds to mandate that these “schools” must function between 9.30 a.m. and 12.30 p.m. and shall not function for longer than three hours in a day. So working women who hitherto used the play schools, crèches and day care centres for childcare will now have to work part-time or not at all. In addition, the draft prevents any child under one-and-a-half years of age from being admitted in any institution for informal education. By their definition, singing a song or playing peek-a-boo with the baby constitutes “informal education”. And that will bring all child care institutions under this regulatory framework, and these institutions will operate in clear violation of the regulation. What then happens to a working mother who has infants? How can these mothers work without adequate care for their children?
Tamil Nadu has among the lowest percentage of working women in India, at 12 per cent of the State’s population. On the one hand, the Tamil Nadu Government is committed to making women more financially independent through various schemes. And on the other hand, we have a draft code of regulations that inadvertently prevents sections of women from working at all. Further, nuclear families account for 74.38 per cent of households in the State — a family structure characterised by the lack of childcare support. Day care centres play an important role in helping young mothers from nuclear families return to work. Most companies offer maternity leave of three months and, at the most, six months. If children less than 18 months of age are to be excluded, where will these working mothers go?
It has been a long road for Indian companies to increase participation of women in the workforce, which remains at a dismal 27 per cent. Among the G20 economies, India ranks second lowest in women’s participation in the workforce. Several IT/ITES companies allocate huge budgets to create diversity teams and workforce benefits just so that more women can work. Among them is creating high-quality childcare crèches at the workplace for working mothers.
Jyothi Rao, a delivery head at a multinational IT major, owes her high-flying career to her company’s onsite child-care centre. She says, “The onsite day care was perfect. I would get to work with my baby in the morning, and would drop in to see him at lunch time. We would go home together in the evening. He is eight-years-old today, but he grew up at the child care centre within my office and is such a happy, confident boy. I owe my career to my company’s foresight and support.”
With the new regulation, there is the end of that! The fundamental objective that children should be in close proximity to where their mothers work is called into question with this code.
Disconnect in National policy
The National Policy for Early Childhood Care and Education (ECCE) was adopted in November, 2013, with a framework for capacity building and regulation of all institutions that serve children under six years of age. The National ECCE Policy takes a holistic approach to the care and education of pre-school age children, which is the internationally accepted norm. The current Regulation seems to have ignored the National ECCE Policy on the definition of the children’s age groups, their vision or their raison d’être. The current regulation is in complete contradiction with anganwadis , other ICDS schemes in the State and the Rajiv Gandhi National Crèche Scheme. For instance, anganwadis in Tamil Nadu operate between 10.00 a.m. and 3.15 p.m. with a structured curriculum through that time. So what happens to the 54,430 anganwadi centres in Tamil Nadu now? Or to the numerous crèches run within the Central and State Government offices everywhere?
The regulation also prevents parents from making a free choice of preschools that they would like their child enrolled in. By mandating that preschools only take in children within a one km radius, the regulation ends up curtailing parents’ right to raise a child the way they deem fit.
Clearly the regulators have drafted this code with the lens of school regulation. Their assumption is that teacher-led instruction is the medium of education for this age group. It further appears that regulators view this type of instruction to this age group as acceptable. How else can we explain the regulators’ mandate to have a break of 15 minutes for every hour? Further, how else can we explain the draft’s constant references to “teachers” and the “School”? Or to mandate a “door near the teacher’s end of the classroom”? A typical early education/ preschool teacher is constantly moving around the classroom; there can be no assigned space for a teacher in such a classroom.
Early Childhood Care and Education is fundamentally based on providing opportunities for children to grow and develop. And this is the vision under which most pre-schools in the city operate. The current regulation threatens to take an existing system, which works at average efficiency, and lower it to regressive standards.
International standards
Internationally, ECCE standards are created with a vision to holistically develop children, while providing support to parents. For instance, Ireland enumerates various types of care and education for children under six, including a “night-time care” policy. Each of these types of care has clearly articulated ratios, spaces and expectations from service providers. The regulation goes to the extent of mandating the type and sizes of furniture that are required to be placed at these centres. Malaysia clearly makes a distinction between childcare centres and preschools or kindergartens. Malaysian regulators are clear that kindergartens may only operate for children between four to six years of age, and childcare centres may operate for children below four years of age. For each of these types of establishments, clear regulations are articulated including classrooms sizes, quality of play materials, extent of fire safety, curriculum framework etc.
The draft has missed research on international best practices on regulation of play schools. Therefore it does not address crucial points such as safety of children’s play materials or classroom sizes. The code, while mandating that all preschools operate only from the ground floor, fails to take note of the reality of preschools in the State. Like the U.S. State laws, the regulation could allow childcare centres on floors I and II but prepare a detailed set of rules on how to maintain stairways, windows, exits and prepare a clear evacuation plan. Clearly the current regulation on play schools needs more work. The regulators must research international standards and our own national frameworks to create regulations that benefit the child and the parent. It’s time we put the child and his/her mother first.
Vasantha S. is an activist and works with several NGOs in Chennai towards the welfare of underprivileged children. vasantha30444@hotmail.com.
Visit http://www.tn.gov.in/schooleducation/draft_regulations/draftcode_regulations_playschool_090615.pdf for the complete Draft Code of Regulations for Play Schools, 2015.
