Wow that is extremely not safe! Car seats are tested for certain weights in certain positions and there are limits for rear-facing for a reason. I just put my youngest in a forward facing seat and he's 14 mths. It's a tricky situation for sure. You don't want to seem like you're telling the parents what to do, but on the other hand, it's the safety of the child. I think as a provider, we have an obligation to say something if there is something the parents are doing that could endanger their child.