North Carolina's ITS-SIDS training requirement, and the seven other staff credentials a visit asks for

The ITS-SIDS requirement, stated exactly

North Carolina requires that "at all times, one child care provider who has completed ITS-SIDS training shall be present in the infant room while children are in care" — 10A NCAC 09 .1102(f) (NC credentials rule set, verified against primary text 2026-08-10).

The same rule sets the timing: the training must be completed "within two months of an individual assuming responsibilities in the infant room and every three years thereafter."

Read that clause twice, because it contains the thing directors most often get wrong.

The clock starts at room assignment, not at hire

The two-month deadline is anchored to assuming responsibilities in the infant room. It is not a two-month onboarding deadline that every new hire runs in parallel.

In practice that means:

• A new hire who starts in a preschool room is not on an ITS-SIDS clock at all.
• The same person, moved to the infant room eighteen months later, starts a fresh two-month clock on the day of that move — not retroactively from hire, and not never.
• A long-tenured staff member covering the infant room for the first time is in exactly the same position as a brand-new hire would be.

This is an event-anchored obligation, and a hire-date spreadsheet cannot represent it. A centre tracking ITS-SIDS from hire dates will show a clean sheet while an infant room is covered by somebody whose clock it never started.

The three-year renewal, by contrast, is an ordinary interval: "every three years thereafter."

What KinderBee does. We carry the rule and its three-year renewal, we evaluate the coverage duty — whether a credentialed person is actually present in each infant room — and, as of CHA-781, we compute the initial two-month deadline from the actual day someone is assigned to the infant room, not from hire date. Record the room assignment and the clock starts from the real event the rule names; leave it unrecorded and we score the duty as unmet rather than guessing — we would rather ask you to log the date than quietly give credit for a clock that was never shown to have started.

ITS-SIDS is a coverage duty, not a per-person checkbox

.1102(f) does not require every staff member in an infant room to hold ITS-SIDS. It requires that one credentialed provider be present, at all times children are in care. That makes it a live staffing question — who is in the room right now — in the same way a ratio is, rather than a records question you settle once a year.

One scoping detail worth knowing: the rule says "infant room" without defining an age cutoff in .1102(f) itself. KinderBee expresses an infant room as a room holding a child 12 months or younger, matching 10A NCAC 09 .0606's definition of the infants the safe-sleep rule covers. That is our reading of how the two rules fit together, not a number quoted from .1102(f).

North Carolina's second event anchor: playground safety re-arms on a vacancy

There is a second place where North Carolina anchors a deadline to an event, and it is stranger than the first. 10A NCAC 09 .1102(e) provides that "staff counted to comply with this Rule shall have six months from the date of employment, or from the date a vacancy occurs, to complete the required safety training" (NC credentials rule set, verified against primary text 2026-08-10).

A vacancy re-arms the clock. Somebody leaves, and the six-month window opens again for whoever is counted to cover that role — an obligation triggered by a staffing change, not by anyone's hire date or certificate expiry.

What KinderBee does. We carry the rule, and, as of CHA-782, we compute the six-month deadline from whichever is later: the day a person started covering the room, or the most recent day someone else covering that same room stopped (a vacancy). Leave a departure unrecorded and we score the duty as unmet rather than quietly reading a departed holder as still covering the room — the same fail-closed posture CHA-781 gave ITS-SIDS above.

First aid and CPR: campus-wide, not per room

Both are coverage duties like ITS-SIDS, but at a wider scope — and this is the distinction that changes how you schedule.

• First aid — "at all times when children are in care at least one staff member present must have successfully completed First Aid training," 10A NCAC 09 .1102(c). Due within 90 days of employment.
• CPR — "at all times when children are in care one staff member present must have successfully completed CPR training," 10A NCAC 09 .1102(d). Due within 90 days of employment.

Both NC credentials rule set, verified against primary text 2026-08-10.

One credentialed person per site satisfies each of these, where ITS-SIDS needs one per infant room. A centre with a single first-aid holder meets .1102(c) and can still breach .1102(f) in two of its three infant rooms.

Neither rule states a fixed renewal interval. .1102(c) requires the certification be "renewed on or before expiration of the certification" — so the certificate's own expiry date governs, and we assert no interval of our own rather than inventing the common two-year certificate term. Track the dates on the cards your staff actually hold.

North Carolina also bars distance learning for CPR. That is a real constraint on how the credential may be earned, and our model records that a person holds CPR, not how they obtained it — so a card we show as valid could have been earned a way North Carolina does not accept.

The criminal history qualification letter

Child care providers "shall have a valid qualification letter prior to employment" (10A NCAC 09 .2703(e)), and "the qualification letter shall be valid for a maximum of five years from the date of issuance" (10A NCAC 09 .2703(n)) — NC credentials rule set, verified against primary text 2026-08-10.

Five years is also the federal background-check re-check floor at 45 CFR 98.43(d)(2)(ii) (FEDERAL credentials rule set, verified against primary text 2026-10-01), so for North Carolina the two agree and the interval you follow is North Carolina's own. Federal law adds nothing here. If you want the mechanics of how a federal floor interacts with a state interval — and the states where it changes the answer — see how often daycare background checks need to be renewed.

Not modelled, and it affects who may be left alone with children. 10A NCAC 09 .2703(f) requires a provisional provider — someone working while their own check is pending — to be supervised at all times by a person whose check cleared within the past five years, and never to be left alone with children. That is a supervision gate, not a credential, and KinderBee does not enforce it.

Health records

All three sit at 10A NCAC 09 .0701(a) (NC credentials rule set, verified against primary text 2026-08-10):

• Medical report — "a statement signed by a health care professional that indicates that the person is emotionally and physically fit to care for children," due prior to employment, and "not older than 12 months" when submitted.
• Tuberculosis test or screening — results "shall be obtained within the 12 months prior to the date of employment," due on or before the first day of work.
• Annual health questionnaire — "due: annually following the initial medical statement," so a twelve-month interval.

The medical report's freshness test is a shape worth separating from an expiry. "Not older than 12 months when submitted" is a test applied once, at submission — it does not mean the report expires annually thereafter. KinderBee does not enforce that submission-time test; the annual questionnaire's twelve-month interval is the only recurring health clock we carry.

North Carolina also requires the staff medical file be maintained separately from that staff member's individual personnel file (10A NCAC 09 .0701(d)) — an access-control requirement that shapes your recordkeeping regardless of what software you run, and one our schema does not enforce. See North Carolina for how that sits alongside the state's other requirements.

Orientation

10A NCAC 09 .1101(a) requires "16 hours of on-site orientation within the first six weeks of employment," of which "six hours ... within the first two weeks" (NC credentials rule set, verified against primary text 2026-08-10).

That is two deadlines, not one. KinderBee models only the outer six-week deadline — the two-week milestone has nowhere to live in the current model, so a new hire who has done no orientation at all in week three will not be flagged for the six-hour deadline they have already missed.

The eight requirements at a glance

All citations in 10A NCAC 09; NC credentials rule set, verified against primary text 2026-08-10.

Requirement	When it is due	Renewal	Coverage	Citation
Criminal history qualification letter	Prior to employment	5 years from issuance	Per person	.2703(e), .2703(n)
ITS-SIDS training	2 months from assuming infant-room responsibilities	3 years	One present per infant room	.1102(f)
First aid	Within 90 days of employment	Certificate's own expiry; no interval set	One present per site	.1102(c)
CPR	Within 90 days of employment	No interval stated	One present per site	.1102(d)
On-site orientation (16 hours)	Within 6 weeks; 6 hours within 2 weeks	—	Per person	.1101(a)
Medical report	Prior to employment; not older than 12 months at submission	—	Per person	.0701(a)
Tuberculosis test or screening	Within the 12 months before employment	—	Per person	.0701(a)
Annual health questionnaire	After the initial medical statement	12 months	Per person	.0701(a)

What we do not track

Stated plainly, because a reference page with no gaps is not a reference page.

• .1101(a)'s two-week, six-hour orientation milestone. Only the six-week outer deadline is evaluated.
• .2703(f)'s provisional supervision gate — a supervision requirement, not a credential.
• The CPR distance-learning prohibition. We record that the credential is held, not how it was earned.
• The medical report's not-older-than-12-months-at-submission test.
• .0701(d)'s separate-file requirement is a recordkeeping control our schema does not enforce.
• North Carolina's annual ongoing-training hours are a separate rule family with its own verification status, and no claim about them is made on this page. See North Carolina for the per-family picture.

One more thing about every credential above: in KinderBee an unverified record counts for nothing — not toward a coverage duty, not as satisfying a requirement in an inspection packet. Only an administrator can verify one, never their own, and editing the dates withdraws the verification, because whatever was checked, it was not that.

And the boundary on all of it: we are at a pilot, disclosed stage. We show you what 10A NCAC 09 requires and when a record stops satisfying it. We do not certify that your centre is compliant — a licensing visit assesses your centre, and 45 CFR 98.42(b)(2)(i)(B) makes it unannounced.

Same state, other rule family: the annual training side of the same staffing question is on its own page — How many annual training hours does North Carolina require?. Its claims rest on North Carolina's training rule set, versioned and verified separately from the credentials rule set this page states.

How to check us

These rules were read from the North Carolina Office of Administrative Hearings' own published text (reports.oah.state.nc.us), not a secondary paraphrase or a commercial mirror. Every clause quoted above was confirmed verbatim in the pass recorded 2026-08-10.

Start with North Carolina for ratios and training alongside these credentials, or the state reference library for the other states we model and which of their rule families have been verified against primary text.