ChildForum Office of Pre-Primary Education

ChildForum Office of Pre-Primary EducationLead advisor on early childhood care and education 
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2008 Regulations: Closed Door Sleep-Room Requirement

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Important Update: In 2009 the Minister of Education and the Ministry of Education reviewed the new regulations and criteria, and this requirement was changed to make it optional for centres to have a closed door on their sleep rooms. This was the main issue of debate.  Unfortunately the change also made it optional for centres to have a separate sleep room instead of just simply allowing for flexibility for sleeping arrangements for individual children.

We have published this article to give you background information on what was an important debate.  


Early Childhood Regulations and the new requirement for closed-door, noise and temperature controlled sleep arrangements for under-two-year olds 

By Sarah Alexander (published August 2008)


We take for granted or assume that criteria for early childhood regulations must naturally be based on at least one of the following things:

  1. Commonsense – what’s practicable, reasonable, and rational
  2. Knowledge of best practices within early childhood services – what works well especially for diverse children and families, and also staff, in the individual settings
  3. Knowledge obtained from thorough reviewing and skilled analysis of pertinent research.

State regulation of early childhood services is typically for the purpose of child protection and may also be for developmental enhancement. Through the regulatory system the government fulfils its protective role by setting and assuring a common baseline of standards and practices for health, safety, and child development.

On Friday 25 July 2008 the criteria for New Zealand’s latest set of early childhood regulations were published on the Ministry of Education website.

It only takes a quick scan of the regulations to see that not all of the criteria meet three, two, or even one of the expectations listed above. In this article, I will discuss one criterion in particular, PF37 (or PF 35 as it was known in the draft new regulations) that seems to fail on all three expectations.

PF37 ALL-DAY SERVICES ONLY: There is a room available (separate to any activity space) to support the provision of restful sleep for children under the age of two at any time they are attending. This room: is able to be closed off from activity areas so that fluctuations in temperature, noise and lighting levels can be kept to a minimum; has a viewing window to allow visibility from another area of the service; and is large enough to accommodate at least the requirements of criterion PF38, when arranged in accordance with criterion HS10.

Note that there are separate licensing criteria documents for ‘Early Childhood Education and Care Centres’ and Nga Kohanga Reo, but the criterion is identical in both documents.

The closed sleep room criterion is a requirement that has not been stated in previous sets of regulations. Previous regulations have permitted flexibility for the outcome of restful sleep to be achieved, and in ways that work best for individual children and centres. Previous regulations have also specified that children resting/sleeping should be within the sight of a staff member at all times, whereas PF37 requires only a viewing window to the sleep room. The Education (Early Childhood Centres) Regulations 1990, for example, state:

The licences of a licenced centre shall ensure that where children under 2 attend, or where children over 2 attend for more than 4 hours on any day, the centre has adequate space and facilities, to the satisfaction of the Secretary, for undisturbed rest for those children. ….  The licensee of a licensed centre shall ensure that all beds used for children are so spaced or arranged as to ensure hygiene, safety, and adequate means of access. … shall ensure that all children resting or sleeping are at all times within sight of a staff member.

My first thought on PF37 (called PF35 in its draft form) when approached by a coalition of early childhood groups for my reaction to it, was that there was no problem. An additional room would be nice to have in any centre building and the extra indoor space and privacy of a closed room could well be useful for other purposes too.

However it became clear on reading the wording of PF37 that such a requirement went against the cultural practices for infant sleeping of some groups and families. It would present financial costs to services. Also, it would reduce space needed for other purposes in centres with already limited indoor and outdoor space.

Most worryingly, it would place infants at risk of harm, emotionally and physically. Restful sleep for infants can be achieved in a variety of ways, and a closed sleep room is only one way - for which there are strong arguments because it is believed children should learn to sleep separately from birth, just as there are strong arguments against because it may explain why some infants develop sleep-related problems (Jenni & O’Connor, 2005).

PF37 requires the provision of a viewing window to the closed sleep room. But a viewing window is not sufficient on its own to ensure safe supervision especially if there are rows of cots and bedding limiting visibility of babies’ faces and sleeping positions. There is no requirement for a sound monitor. There is no requirement for an adult to be present by the viewing window at all times, or in the room. PF37 is likely to be interpreted by officials as necessary for all centres to make use of sleep rooms, and will lead to all services being more likely to use closed sleep rooms for infant sleeping regardless of infant preferences, and parental, cultural, professional and programme beliefs.

website_13PF37 reflects a particular cultural view of infant sleep practices that is not necessarily valued or seen to be best practice across all families and cultural groups in NZ.

I think back to how my first child was very gently rocked to sleep in a pram in the play area when he was at a university crèche. Everyone watched over him while he slept and the minute he woke up there was always an adult to smile and greet him.

I thought about seeing a closed sleep room at a preschool later and feeling pleased that my son was now too old to need to sleep and be put into this room at the end of the centre building without someone to care for him.

I recalled visiting a local Pacific Island language nest whilst filming for the ‘Choices for Children’ video and seeing children of all ages sleeping peacefully and restfully on mattresses on the floor, undisturbed by our low voices and tiptoeing, and waking and rising only as they wanted. 



The research to which the Ministry of Education referred in drafting PF37 provided an insufficient evidence base to conclude that all all-day early childhood services licensed for children under the age of two must (or even should) have closed sleep rooms.

The majority of references in the Ministry’s bibliography were not references to relevant research. Out of the list of 50 references, 38 were references to popular articles such as from ‘Little Treasures’, general advice and opinion pieces, government guidelines for services in NZ and overseas, or were articles of no relevance (e.g. about children’s sleep disorders and treatment; sleep in hospital critical care and neonate units, and research around the debate of infants co-sleeping with parents at home). A further 2 references could not be accessed for review but, from their titles and Ministry notes for one of the references, it seems unlikely that the articles supported the concept of closed sleep rooms in early childhood centres. Of the remaining 10 references in the Ministry’s bibliography, 6 of these were point-of-view papers and research papers that made points of possible interest to discussions and thinking about sleeping arrangements in early childhood centres. Just 4, including 2 references by the same author, were research studies specifically on sleep arrangements in early childhood centres. Thus, the Ministry had a very thin evidence base at hand when it formulated the closed sleep room requirement.

What is interesting is that amongst the literature sourced by the Ministry of Education there does not appear to be evidence supporting the need for closed sleep rooms for 0 – 2 year old children. Instead, there is some evidence to the contrary. A common thread in the literature was that children’s individual needs and family culture should inform/guide the sleep arrangement and that infants can have restful sleep in open rooms.

Let’s look at the references in the Ministry’s bibliography for PF37 that were research studies of relevance. Two references were to overseas studies and two were to a single study by New Zealander Michelle Pratt.    

First, Twardosz, Cataldo, & Risley (1974) carried out a series of experimental studies. The researchers found that an open environment resolves the problem of visibility and ease of monitoring of children (and monitoring of staff safe practices with children by the supervisor) compared to a more closed sleeping environment. An open environment was not found to affect the sleep of infants adversely. “However, an open environment, which is ideal for ensuring the visibility of older children as well, may not be conducive to the sleep of ‘toddlers’, who are beginning to walk and talk.” An age difference was found. The toddlers were observed to sleep for about as long in the open play area as in the dark closed room, but took slightly longer to fall asleep and awaken in groups.

Second, Siren-Tiusanen & Robinson (2001) report a study that involved three case studies of sleeping in two Finnish daycare centres for infants and toddlers. The findings showed that major differences existed between day-care and home practices regarding the quality of sleep and its physiological effectiveness. These differences were related to: (1) whether the timing of naps in the multiage (infant – age 3) group is simultaneous or staggered in an age-appropriate and individually appropriate manner; (2) how efficiently the parents and teachers/caregivers communicated with one another; and (3) the awareness level of the day care staff about the significance of the sleep environment. The authors recommend that optimal sleep environments take children’s individual needs into account, understand children’s sleep patterns and needs, and reduce potential environmental disturbances such as people coming and going from the sleep area.

Third, Michelle Pratt’s research (2004) for her Graduate Diploma in Educational Management (ECE) at UNITEC provides a case study of one early childhood centre and describes an action research process to improve the sleep environment. Prior to carrying out the study, Pratt believed that closed sleep spaces were best but the evidence challenged her long held views. Pratt concluded that:

Sleep environments open to the main play areas for early childhood centres for infants and toddlers work extremely well. Preconceived ideas of staff and parents with little research have led us to build closed off sleep areas. (p. 65)

The changes that were implemented at Toddlers Turf Childcare Centre Inc were extremely effective. Sleep areas are now open to play spaces. Staff are more aware of children’s individual needs and requirements for sleep. Children are now supervised at all times, checking systems for the monitoring of sleeping children have been removed as all children are supervised at all times. (p. 67)

In conclusion, an analysis of the references the Ministry of Education drew on in formulating PF37 (then called PF35) shows that PF37 cannot be claimed to have had justification in research.



This paper argues that Government regulations for early childhood centres should meet expectations for being based on common sense, knowledge of best practices, and knowledge obtained through a thorough and skilful review of research evidence before a new requirement becomes law. Clearly this was not the case with PF37.

PF37 was formulated without an adequate evidence base. But perhaps it was not meant to reflect and be informed by research or common sense and best practice. It could instead be about managing the early childhood sector in the same way that the primary and secondary sectors are managed, i.e. through central control. Closed sleep rooms were already being enforced in some areas of NZ. The introduction of PF37 simply allows now for the streamlining of enforcement across the country. Such streamlining is a top-down approach to regulation to manage diversity and difference in needs and practices. This is something that should be of concern to all within the early childhood sector.

The wording of PF37 also reflects a personal-cultural view on how infants should sleep, whereas it could be possible to regulate for the outcome of peaceful sleep and allow for this to be achieved in ways that work best for individual children, families, and their centres. The advice that Jenni and O’Connor (2005) gives to researchers and clinicians (paediatricians) in the area of young children’s sleep would also be useful for those who write and enforce early childhood regulations:

"… clinicians and researchers should attend systematically to their own cultures’ values and preferences and to the ways in which they condition their responses and expectations." (p. 214)



Blau, D.M. (2007). Unintended consequences of child care regulations. Labour Economics, 14(3), 513-538.

Jenni, O.G. & O’Connor, B.B. (2005). Children’s sleep: An interplay between culture and biology. Pediatrics, 115(1), 204- 214.

Pratt, M. (2004). Investigating and improving sleep rooms for infants. A project in partial completion of the Graduate Diploma in Educational Management, UNITEC, New Zealand.

Siren-Tiusanen, H. & Robinson, H.A. (2001).Nap schedules and sleep practices in infant-toddler groups. Early Childhood Research Quarterly, 16, 453-474.

Twardosz, S., Cataldo, F., & Risley, T.R. (1974). Open environment design for infant and toddler day care. Journal of Applied Behaviour Analysis, 7(4), 529-546.



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