Pg. 32  All staff who work directly with children shall have within 30 days of the date of employment CPR & First Aid certification.

As stated in the CCDBG guidelines which has been the driving force behind some of these new proposals, all staff shall be "trained" not "certified" in CPR & First Aid.  (Page 67583 in the Federal Register) I support 100% of staff to be "trained" and for 50% to be certified.  This would allow one staff to perform CPR or First Aid while other staff care for the rest of the children.  I also request a 90 day (not 30 day) grace period for new staff requiring certification.  Please note my suggestion of 50% staff certification is a significant improvement to the current standard of one staff.  Requiring 100% of staff to be certified will undoubtedly have a cost factor tied to it which would be passed on to parents!  For many, many years our licensing standards were titled "Minimum Standards for Child Care Centers".  Although the word "minimum" has been dropped from the current title, the idea still remains!  If centers want to certify 100% of their employees in CPR & First Aid there is nothing to prevent them from doing so.  This is the case for many standards.  Centers can often do more than required and they usually advertise accordingly to separate themselves from other centers.  I'm asking you to create standards that keep children safe while at the same time considering cost analysis factors to the many parents that struggle to pay child care expenses.  Please leave room for the free market to operate.