40-185-220B:  Adding the language “aides under 18 shall not be left along with children” is too broad and restrictive, especially for smaller daycares.  We would like to see an exception for smaller classrooms and daycare centers.  As our rooms are small and close to each other, we are able to hear what is taking place in each classroom from the main office. If anything, we would like for it to say “aides under 18 shall have sight or sound supervision.  That way they can be left alone in a classroom, but not entirely left alone without supervision.  As the requirements for a program leader/lead teacher must be 18 years of age, an aide under 18 would not be the main one responsible for teaching/instructing the children for most of the day anyway.  This way they could be used during rest time, absence of the lead teacher for short period of times, or during pick up and drop off times.

Regarding 40-185-245A about increasing the annual training to 20 hours.  We would like to see an exception for part-time and substitutes just like short-term program which only need 10 hours of training a year.  It is already a challenge to obtain the 16 hours of training for full-time employees.  It is almost impossible to find a part-time employee or sub who is willing to do 16 hours of training each year. Increasing the hours to 20 hours across the board for all employees too demanding and is setting the daycare center up to fail.

With all of the required training that needs to be completed already for new staff, adding the requirement that all staff shall have CPR and first aid within 30 days of the date of employment as outlined in 40-185-530A is excessive.  I can see having more than one person on the premises at all times would be needed, however, making it a requirement for all staff to have this training and to obtain it within 30 days of employment is excessive.  It would be more obtainable to require all program leaders/lead teacher to have CPR and 1st Aid training and extend the time frame to at least 90 days of employment.  Aides, part-time employees, and subs should not be required to have this training.