Please consider reducing the training requirements for substitute teachers (a category of staff not currently defined in the regulations).  It is difficult for small preschool programs to ensure an adequate roster of substitute teachers because they must meet all staff training requirements yet may only work limited hours. For instance, at our school a substitute teacher rarely works more than 12 part-time days per academic year.  It will become even more difficult to find people willing to undergo a 16-hour orientation training plus 20 hours of annual training requirements in order to work 40-50 total hours during the entire school year.  

RECOMMENDATION   The regulations should define substitute teacher/staff, and provide a sliding scale of required training hours for substitutes, commensurate with the number of hours worked per year.