Jordan called that "a terrible accident waiting to happen."
Spokesman Fernando Gallard said the district was reviewing the complaint and would be prepared to answer questions from the state.
"The district is confident that its long-standing practice and its protocols for administration of medication fall within the requirements of law and fully address the medical needs and well-being of children in our schools," Gallard said in a statement.
In the complaint, the union cites "wholesale violations" of provisions of the Department of Health's Guidelines for Pennsylvania Schools for Administration of Medications and Emergency Care.
Specifically, the district has violated the state's rules by directing nonmedical professionals to administer medications and by requiring school nurses to train other staffers in how to give medications, the union said.
When certified school nurses aren't available, medication is handed out by principals, gym teachers, counselors, community liaisons, secretaries, and even aides who normally monitor the playground, the PFT found.
One veteran school nurse now works at three schools, including one busy elementary school with more than 1,000 pupils. The school used to have two nurses.
"When I'm there by myself, I see over 30 kids for illnesses and injuries, and 20 more for their meds," said the nurse, who asked that her name be withheld. "I have diabetics - some who are noncompliant - a tube feed, many special-ed students."
Just covering the students' basic needs means things the state mandates that nurses do - vision screenings, immunization checks, height and weight checks - must wait.
And the school has a sizable number of English-language learners, some of whom have no other medical care.
The one day a week she works at one of her other schools is the only day that school, which has about 500 students, has nursing care. When the nurse isn't there, a secretary is the nurse-designee - a problem because she is not a medical professional, the nurse said.
"Other people aren't listening for lung sounds. They can't make medical assessments," she said.
Robert McGrogan, head of the district's principals' union, worries about the implications for his members.
"This is a dire financial situation," McGrogan said. "I appreciate that. But it doesn't mean that we can just arbitrarily and capriciously put people in situations they're not certified to handle."
Lauren Perez has two boys in public school. The younger one has Type 1 diabetes and receives regular insulin injections.
"My son, who is very healthy otherwise, could simply go into a low blood sugar coma and die," Perez said. "The only person who can give him a lifesaving shot is a nurse."
That son is covered by a nurse. But her older boy is in kindergarten at Dobson Elementary, which goes without nursing services most days.
"There's another diabetic child at Dobson, but no full-time nurse. How safe is that?" Perez asked. "As a parent, you send your child to school for six hours and you believe that they're cared for medically. But that's not necessarily the case, and it should be. What's going to happen in an emergency?"
Underscoring that point, dozens of school nurses and their supporters gathered on the steps of the district's North Broad Street headquarters Wednesday to call attention to the cuts.
It was the fifth week in a row the nurses had gathered. They have said they will continue to protest until their concerns are answered.
Contact staff writer Kristen Graham at 215-854-5146, firstname.lastname@example.org or on Twitter @newskag. Read her blog, "Philly School Files," at www.philly.com/schoolfiles.