As a toddler lead teacher who has trialed the group sizing I object to this regulation.  I teach toddlers 18 months and up and follow the 1-5 state ratio requirement with a classroom of 20 children.  When we trialed the group sizing in my classroom it caused many issues. We used 21 inch bookshelves to seperate the groups and assigned 2 staff members to each group.  During this time we had to have two seperate circle times for each group which as you can imagine made it difficult for the students to concentrate as two groups are doing different things only seperated by a shelf.  The children could see and hear the other students and many didnt understand why they were not allowed to play on the other side with their friends.  Parents were highly upset wondering why their child was in the group without the lead teacher,  If children were seperated by ability or if teachers picked who they got.  They also voiced concerns with who was in each group and if they could be switched to be with their friends. This caused problems for management as parents were complaining and were not happy with the seperation of the classroom. I also had two children who required medical attention as a result of the group sizing.  Toddlers are not walking confidently and "toddle" around often falling and with the large bookshelves restricting the area that they are used to playing in I had one student hit their forehead and needed stitches and another child who hit their lip and had to be checked by their doctor.  The trial caused nothing but issues in my classroom and would not work constructively in an environment with multiple groups. My class would be forced to cut spots and take childcare availability away from families in need. 

I also object to requring staff under 18 to be supervised by other staff. To me this creates an atmosphere where one staff member will be sitting around who can be better used in another room or relieved for the day.  The younger employees are often very enthusiastic about playing with the children and pleasing the parents and more often than not are more reliable that someone who has worked 8+ hours with the children all day.  They come in after school and are refreshed and ready to work which relieves some of the fulltime employees who have been working since 630 am.