Duster: Section 4 (a) (i):
  1. “Attendance as supervisors” requires that the person must be present and actively circulating through the areas in which services are being provided, in order to monitor all activities for appropriate behavior.

The key words are "actively circulating through the areas" if they are doing any other task, then they are not actively circulating or observing. Their task is supervision and nothing else. If you are helping parents with paperwork, you are not supervising or circulating and not in observance of what is going on.

Where we do our events, there is very limited aircraft parking. We have to share it with the fueling area, the restaurant transient parking, auto parking, the junction of three taxiways and the entrance to the runway. We have had to park aircraft on the far side of the main taxiway due to space limitations and in some of those areas, it is completely out of sight of the meeting location due to the sheer number and size of aircraft. Taking multiple kids on the ramp while at the same time loading, unloading and being sure they are safely belted in takes more than one set of eyes outside the aircraft besides the pilot. 16-18 year olds, not as much watching is necessary.

The Staff to Youth ratio tells me that is the number required to deal with that number of kids, and nothing else. Every where I've ever been that has any type of staff/kid ratio policy, it has been the practice that the number is the requirement just to oversee the kids and that is their primary responsibility.

You may feel that the policy gives you lots of freedom, but I don't see it that way. I read and have to understand compliance orders and directives every day in my job. If you don't have written guidance giving you more latitude, then to protect yourself you had better adhere to the strictest interpretation, otherwise when there is a problem, he-said she-said is not going to be in your favor.