6VAC20-171-120. Initial registration application.                                                                                                                                                                                                                    B. Each person applying for registration shall meet the minimum requirements for eligibility as follows:

1. Be a minimum of 18 years of age;

This regulation would not allow apprentice training for school children and is in direct conflict with a State Agency known as the Department of Labor and Industry which specifically provides apprenticeship training programs for students in industry jobs for long term training.                                                                                                                    ______________________________________________________________                                                                                                                                                 9.1-140.1. Registration; waiver of examination; locksmiths.                                                                                                                                                                                          Not withstanding any other provision of this article, unless an applicant is found by the Board to have engaged in any act that would constitute grounds for disciplinary action, the Board shall issue a registration, without examination, to any applicant who provides satisfactory proof to the Board of having been actively and continuously providing locksmith services immediately prior to July 1, 2008, for at least two years.

  Federal law allows for maternity, guard duty, moving time and other possible needs in the every day lives of its citizens. The term continuously in the case of the D.C.J.S. has not been defined and as not shown to be flexible in its application of this regulation to its citizens.                        _____________________________________________________________                        _       Chapter 225 code of Virginia 9.1-140

H 2644 March 27,2009

Item 28 Any individual, employed by a retail merchant that also holds a private security services business license as a locksmith, where such individuals duties relating to such license are limited to key cutting and the key cutting preformed under the direct supervision of the licensee.

Code 9.1-138 Definition “Electronic security equipment” means electronic or mechanical alarm signaling devices, including burglar alarms or holdup alarms or cameras used to detect intrusion, concealment or theft to safeguard and protect persons and property.(This shall not include tags, labels, and other devices that are attached or affixed to items offered for sale, library books, and other protected articles as part of an electronic article surveillance and theft detection and deterrence system.)                                                                                                                                   

The Technology in a key today is described in the above red outlined section. This appears to me to say that a single Compliance officer with the business that holds a category locksmith license can operate a lock shop and have many employees programming car key and making keys for lock and other related jobs as long as they are part of the theft deterrence system.