July 3, 2000

Natasha Metcalf, Commissioner

Children’s Protective Services

Tennessee Department of Human Services

400 Deaderick Street

Citizens Plaza Building

Nashville, Tennessee 37219

Dear Commissioner Metcalf;

This letter expresses some concerns and questions I have concerning parts of the Personal Safety Curriculum that is required to be taught in day care centers licensed by the Tennessee Department of Human Services.

I am very concerned about are about theTouch Safety stories in Lessons 7 & 8*, that are to be read to children in the centers. These stories are sexually explicit.

Is it not sexual abuse to read sexually explicit stories to children under age twelve in the state of Tennessee?

I am also concerned about

1. the effects that reading these stories to children might have on them
2. the chronological way of determining which children should have these stories read to them

3) whether all parents are aware of the content of the stories being read to their children and whether all parents have the opportunity to opt their children out of hearing these stories

Concerns about the effects Lesson 7 & 8 stories might have on children:

Reading these stories to children could qualify as sexual abuse in that they make children aware of sexual matters that are not age appropriate.

1. Such stories may rob children of innocence during a period of sexual latency.
2. Such stories could cause children to worry, dream, be suspicious, etc.
3. Perhaps such stories are behind some of the false memories and false accusations of children.
4. Since I would not read a story to young children about proper sex (how mommies and daddies may touch each other) I would not read a story about improper sex.
5. Talking about sexual activities and naming sexual organs in the company of both boys and girls breaks down the natural modesty that should exist between the sexes.
6. Talking about sexual matters in groups makes what is a private matter into a public matter.

It seems to me that parents are the proper persons to teach children the names of their sexual organs and to teach them about proper and improper sexual activity. If it is determined that parents have not and will not take this responsibility, instruction regarding the responses to unsafe touches, (saying No, getting away, don’t keep secrets, tell), should be done in very small (2 or 3), single-sex, developmentally appropriate groups.

1) Having reached a certain birth date (age 4 for these stories) does not guarantee a certain level or maturity or readiness.

2) What about children who have missed lessons in the series that may prepare them to be able to handle the introduction of the idea of sexual abuse?

3) Children may also have circumstances in their lives (homes, families, health, etc.) at the time these stories are scheduled to be read that would make it inappropriate to introduce the idea of sexual abuse to the child.

It seems to me that the parent(s) should always be consulted immediately prior to the scheduled reading of these stories and permission granted or denied by the parent. Which brings me to the next concern.

1) Parent letter #1, along with handouts, which are sent to parents who do not attend the parent meeting introducing the curriculum, do not alert the parents to the graphic content of the stories in lessons 7 & 8.

2) Subsequent parent letters are "sent home after each of the five units is presented to let parents know the concepts that have been introduced."

Again, it seems to me that the parent(s) should always be consulted immediately prior to the scheduled reading of these stories and permission granted or denied by the parent.

3) Parent letter #3 states, "We teachers used the names for private body parts that staff and parents at the parent meeting agreed we should use."

Parents who did not attend the parent meeting may be shocked to learn, after the lessons have been presented, what new vocabulary their children have learned.

In addition to responding to the above comments, please answer these questions that I have regarding the Personal Safety Curriculum:

1. Where does DHS get the authority to require day care personnel to read these stories about sexual abuse to young children?

Is there legislation mandating or authorizing this requirement? Tennessee

Law TCA 37-1-603 mandates annual child sexual abuse prevention

program, but is there a legislative mandate for the reading of the stories in

lessons 7 & 8 of this particular curriculum?

2. Is Tennessee unique in requiring the reading of such stories to children in day care centers? If not, how many other states require this?
3. How long has the practice of reading these stories been going on?
4. Have there been any studies done to determine the impact that reading these stories to children has on the children? Do we have any data to indicate that reading these stories to children actually helps them avert sexual abuse? Do we have any data that indicates these stories my cause fear, suspicion, and worry in children? Do we know of any instances where children might have been trying to express their concerns over hearing such stories, but their attempts to communicate were misunderstood to be reports of sexual abuse?
5. Have their been any studies (surveys that could be submitted anonymously, without fear or reprisal, for instance) done to indicate how many day care centers actually do not read these stories to children because the personnel have concerns like those expressed in this letter?
6. How many day care centers have been "punished" by DHS because they admitted that they do not read these stories to children?
7. Do we have any record of the numbers of parents who have objected to having these stories read to their children?

Thank you for your prompt response to my concerns and questions.

(Your name)

(Your address)

(Your phone)

*Content of stories causing concerns
Lesson 7- "He put his hand into her panties and touched her vagina (a private part of her body.)" The story is followed by activities talking about unsafe touches of vagina, penis, and anus.

Lesson 8- "Uncle mark had put his hand inside Matthew’s pajama bottoms and was touching Matthew’s penis (a private part of his body.)" The story is followed by activities talking about unsafe touches of vagina, penis, and anus.