I strongly oppose the change to 22VAC40-185-240 that would require all staff to complete 16 hours of orientation training prior to being alone with children and within 7 calendar days of employment. A more reasonable and equally safe requirement would be for full-time staff to complete a minimum of 16 hours of orientation training and part-time staff to complete 4 hours of orientation training prior to working alone with children and within 7 calendar days of employment. 

Our non-profit center employs several part-time staff to help with lunch break coverage and end of the day ratios.  These college students generally start out volunteering at our center for at least a semester through a local volunteer program, with whom we have been receiving volunteers since the 1980s.  Volunteers who fit in well with our program expectations and interact well with our staff and children may later be hired as part-time staff.  We are flexible with their hours to accommodate their college classes, and as a result, some students only work a few hours a week.  For some of our part-time staff, this requirement would take weeks to complete the orientation with their limited availability, thereby eliminating our ability or desire to hire and utelize these young adults who interact in our classrooms so well and offer strong support to teachers so that they can lower classroom ratios and increase the number of high quality one-on-one interactions between full-time staff and children.