The subject regulation is necessary for the protection of public health, safety, and welfare.

The subject regulation should be amended as follows:

6VAC20-180-30 D - Eligibility:  personnel appointed to crime prevention tasks should be certified within 5 years of appointment.  It is inappropriate for chief executives to permit personnel to perform these tasks indefinitely with no expecation of proper training/certification.  Uncertified practitioners puts the general public and businesses at risk.

6VAC20-180-60 B - Decertification:  holders of the certification should be allowed to keep their certification for the full duration of the certification period (currently 3 years) even if they leave their employment/volunteer capacity - but with no possibility for renewal unless they return to an appropriate capacity.