ChildForum Office of Pre-Primary Education

ChildForum Office of Pre-Primary EducationLead advisor on early childhood care and education 
National membership 

Publisher of the New Zealand-International Research in Early Childhood Journal


New Rules for ECE Special Alert

What we are sharing with you is stuff you need to know now, and to prepare for re-opening.

Below is

  1. A quick note on the financial operating environment and uncertainties (we will keep members updated on this)
  2. Information prepared by Dr Sarah on the new rules for operating at level 3 – the intricacies and what needs to resolved/ sorted out


A Quick Note

As mentioned in Friday’s email to all members and people on our newsletter mailing list, funding and safety are two major issues. (To be added to the mailing list go to the newsletter sign-up box)

Safety must come first. (read more)

Retaining ECE services and keeping teaching teams together is important. We need to ensure that the action of opening under level three (with small child numbers and high operating costs) will not see in the months/ year ahead a significant proportion of services finding that they simply can't afford to keep operating.

It will be difficult to charge parents’ fees when a place for their child cannot be offered and it is for their safety that they stay home.

It will be difficult for services to open and sufficiently staff to meet ratio requirements, when they have staff who are in vulnerable groups, live with vulnerable people or otherwise have legitimate safety concerns about returning to work.

Dr Sarah has written to the Ministry and asked it to urgently please confirm that:

  • funding will continue at current levels for ECE services that re-open under Alert Level 3 and there will be no clawbacks.  
  • if actual numbers of children who attend is less than enrolment numbers, services will not be required to pay this back.
  • in the case of any service that (a) due to staff safety concerns chooses to remain closed under Alert Level 3, or (b) does not need to open because parents choose to keep their child at home, that funding will continue to be paid to the service at pre-lockdown level as is happening at Alert Level 4. 


ECE to operate as Drop and Run Daycare in Level 3

leaving child in childcare - doing the great handover

Dr Sarah Alexander

New rules issued by the Ministry of Education late last night (Friday 17th April) for the operation of services during Level 3 replace some regulations and licensing criteria.

With any luck the number of new infections announced every day by Ashley Bloomfield will be zero when ECE services re-open. This would substantially reduce any worry for parents and whānau. It would help managers and teachers to not feel that they are being treated as expendable, i.e. that the government doesn’t think their safety matters as much as say the safety of supermarket or office workers.

The new rules cover Te Kōhanga Reo, Pacific Island Language Nests, and all Education and Care centres including kindergartens, Montessori, and Rudolf Steiner centres. Playcentres and playgroups are excluded (you will remember that at level 2 some playcentres made a stand and closed to be safe and this has been recognised in allowing Playcentres to continue to be closed and funded until it is safe to re-open).

Home-based educators can resume to care for the children of multiple families in one location under level-3 including the educators’ own children. They must, like everyone else, meet public health requirements.  

Early learning centres will be open to provide childcare for people who are working. Children will not be able to attend Playcentres and play groups. Home-based care, education and supervision of young children for more than one family in a home if public health control measures can be implemented. (NZ Covid-19 Alert Level description pdf)

A little reminder to everyone, to check employment and collective contracts for any agreements on health and safety conditions, to ensure that practices and support for employees provided is in line with and does not breach agreements (Read more)

I will outline what the new rules for centres are, and below the outline I will give some interpretation of the new rules.

Level 3 centre rules

  • Increase indoor room temperature minimum of 16 degrees Celsius to 18 degrees Celsius.
  • Increase the minimum licensed indoor space for children from 2.5m per child to at least 3m per child. Outdoor requirement of 5m remains.
  • The number of children must be limited to 10 in a bubble (this can be increased to 20 when the Ministry says you can increase to 20).
  • There can be multiple bubbles of 10 children on a site but there must be no mixing between bubbles
  • Parents keep any sick children at home. If a sick child comes to the centre, send them home.
  • All children regularly wash and dry their hands.
  • Hand sanitiser is available but teachers/staff supervise its location and use in order to avoid a child accidentally drinking it.
  • Staggered entry and exit times to avoid all children coming into or exiting the centre all at once and parental drop-off at entrance to limit numbers entering site.
  • Children have their own food containers and do not give and take food to and from each other. Food can be supplied in accordance with public health guidance.
  • Meal breaks should be staggered.
  • Put away any toys that cannot be easily wiped down or cleaned frequently.
  • Disinfect and clean all surfaces daily.
  • PPE is not required or recommended as necessary.
  • Contact tracing registers must be set up to record who is on site in each physical space each day, who visits e.g. parents.
    (a pdf of details published by the Ministry of Education can be read online here

Interpretation and discussion

The Ministry of Education says “Children and teens have low infection rates, they don't become that unwell if they do get infected, and they don't tend to pass the virus on to adults.” So, it is okay for services to operate when there is a known virus in the community, there is risk of children becoming ill (but probably not dying) and for teachers / staff to be in close contact because they will probably not get the virus from children.  But adults can pass the virus on - this kind of contradicts current regulations on mitigating the risk that children will be affected by a person with a contagious disease (see what these are here). Note that there is, evidence that children can still be infected and they can transmit the Coronavirus to others. 

“Many think that children are at low risk and we don’t need to worry about them, and yes, that is true for children who don’t have chronic medical conditions like immunodeficiencies. What people are forgetting is that children are probably one of the main routes by which this infection is going to spread throughout the community.” (BBC report)

There is some research suggesting that higher temperature and high relative humidity can reduce the transmission of Covid-19. There is no mention of expectations for the level of humidity in the above list, only that the minimum room temperature is to be raised by 2 degrees Celsius (from 16 to 18 degrees).

Children may be in rooms with less than 2.5m space per child since space is calculated across the centre when it is licensed.  Perhaps the ministry will issue a new rule that space is to be calculated per group/ bubble of children?  However, who will measure this and who will check for compliance?

Because the number of children is limited to 10 initially, the increase in space per child rule will likely mean no change to most centres. There should be few centres that cannot meet the new increased space per child rule when the max is 10 children (unless a centre had been breaching regulations by packing children in with smaller than 2.5m square space per child prior to the lockdown in which case it could be considered a good thing that it cannot open under Level 3 because it can't meet the new space rule). The new rule however, could impact on centres currently licensed for 10 children that have no more than 2.5m per child space available and in this case a centre would limit bubble size to less than 10 children. 

Group size, for the first time, in ECE is being introduced as a requirement (Read more about group size). The group size or bubble maximum is 10 children. There can be multiple groups in a centre. 


  • The minimum ratio would/should be 2 adults to every 10 under 2s, and 2 adults to every 10 over 2s. You legally can’t have 1 teacher only in a centre that has 10 children. However currently ratios are calculated across an entire centre (Go to a chart on how to calculate adult-child ratios
  • Staff children would need to be placed in the same group as their parent/ the staff member (which may cause problems if the child wants to be with their friends in another group)
  • Children would be unable to be grouped according to age, because: 
    * Children from the same family would need to be placed in the same group and not split between bubbles.
    * It would be logical to have those who attend on the same days or at the same times in a group (e.g. morning-only children in a group, full-time children in another group).
    * No new children or adults would enter the bubble from outside of the site or spend time in a different bubble on the site (e.g. a relief teacher would not work in one bubble and then cross over to another bubble). What does this mean for staff getting their breaks? What does this mean for parents who want their child to attend only on some days or for short hours?  
  • Playgrounds will need to fenced so each group or bubble has its own bit of outdoor space.
  • A centre that say has one large room and is licensed for 40 children (such as a traditional kindergarten) could use movable shelves as barriers to break the room into two complete and well-separated halves or separated mini-rooms.
  • Sleeprooms/ bathrooms will be an issue when there is more than one group of children and shared facilities. Maybe bathroom trips could be staggered so basins, toilets, door handles etc. could be thoroughly cleaned after each group use.  But when a child needs to go to the toilet, a child needs to go ….!

Asking parents to keep their children home when sick is not a new rule. But it can be hard to enforce, and especially if parents have used up all annual leave and sick leave and they really, really need to be at work. An article to share with parents on why it's not a good idea to hide symptoms to sneak your child in, can be found here - use of painkillers for fever and hiding symptoms 

Soap is better than hand-sanitiser.  The reason for the Ministry rule to supervise children when using hand-sanitiser is that it can contain alcohol. And yes, a child at an early childhood centre did get drunk on hand sanitiser! (read the story here

Hand-washing and hygiene cannot be expected of babies and this is something that teachers will need to pay careful attention to. Toddlers need assistance and coaching. 

Nappy changing hygiene is not within the rules but it is just as important. At this time disposable nappies may be better than reusable.  And, just because the teacher has gloves on does not reduce the risk of transmission of disease if the hand with the glove on then goes to touch or pick up objects that others may then touch.

How will staggered drop-off’s and pick-ups work?  Perhaps specify a time with 10- or 15-minute gaps for each child to be dropped off.  But what if a family is late?  It is unrealistic to expect all parents to be on time, all the time. Another idea could be for a parent to text when they are outside the door, and for parents and caregivers to keep a metre apart at the entrance.

Passing over children between parent and teacher is difficult when a child is in a parent’s arms or does not want to let go of their parent’s hand! 

After a month or more away many children will need re-settling in. Its going to be emotionally very difficult (for all involved) for parents not to be able to stay for the first hour or day.

Teachers will need to be ready for this and have some pre-prepared helpful advice and suggestions for parents to help to manage the drop-off (get a copy of advice on how to handle the drop-off here)

Many services already require children to bring lunch-boxes. Generally, there are already good practices in place to limit the sharing of food between children and not using the same cups.  (go to lunch-box ideas)

The rationale for staggering meal beaks when there are only 10 children in a group and 2 teachers is not clear. Providing there is no sharing of food, plates, cups, and utensils, having morning/afternoon teas and lunch together would probably be no more risk than any other activity the group may do.  

What about teachers getting their breaks? If a teacher leaves the group, then to maintain ratio another adult should replace the teacher – however that is extending the bubble and the risk is that the adult who replaces then goes into other groups or bubbles.

The rule to put away toys that cannot be easily wiped suggests a minimalist environment.  It is about going back to non-commercial childhood times – taking children for walks, playing group games (e.g. I’m going on a bear hunt, doing the hokey tokey/pokey dance, listening to stories, making things out of paper) and doing social activities.

The rule to put away toys that cannot be easily wiped, suggests that if toys are left out then the teacher must be a cleaner.  In schools, teachers are not employed to be cleaners.

Cleaners should be employed to come in and clean and disinfect all surfaces daily.  Things like chair legs, table edges, places where children crawl and outdoor playground equipment would, one could assume, come under the rule to disinfect all surfaces.

A contact register will be like a visitor book.  But for contact tracing, every person that is on-site at any time, even for a second, needs to be recorded along with their contact details. A person would need to always be on the door or at the entrance if the contact register is to be a reliable record. This could be an extra staffing cost for your centre.  

In Covid-19 times we expect great care to be taken. The above rules issued by the Ministry of Education seem short, just a beginning of what is really required for safety.   

The Ministry has had to rush to develop the rules.  It has said it will provide greater clarification. Let’s hope this reflects more understanding of the special nature of ECE settings, of babies, and young children.

And let’s hope the Government and Ministry of Education shows a lot of sensitivity in its asking of people and service providers to put their own safety and services at risk, for the sake of supporting businesses unable to operate during level-4 to operate during level-3 for the wider good of our economy.

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