To always maintain 100% of staff certified in first aid and CPR is both unnecessary and impractical.  As stated in the CCDBG guidelines all staff shall be "trained."  That does not mean "certified".  Why not ask that 50% of staff be certified?  Is there any research to show that having 100% of staff certified instead of 50% changes the effectiveness?  Even with these requested changes, this is a significant improvement over the current requirement of one staff to be CPR/FA certified.