This requirement is a complete waste of valuable time for a business that has been operating as a locksmith. The department should provide a completely separate class of related regulation for the locksmith industry as laid out in Chapter 638 April 13, 2008 Session act of Assembly page 6 of 6 9.143 Item 2 & 3 2.: That the Criminal Justice Services Board shall adopt reasonable regulations in accordance with the Administrative Process Act 2.2-4000 et seq. to implement the provisions of this act. 3. That in addition to the requirements of 202-4007.01 and 2.2-4007.2, during the promulgation of regulations in accordance with the second enactment of this act, the Department of Criminal Justice Service shall meet with representatives of various locksmith organizations and other interested parties to solicit input from such organizations and persons in the formation and development of regulations concerning the appropriate educational and training requirements for locksmiths.
In my opinion this agency has not tried to take input from the working class day to day locksmith on these matters other than on the comment period of the action. I personally have forwarded a video locksmith school lesson that would be 100% better than the classes they have chosen to use. Based on the last comment period and the comments made I don’t see any significant changes. The only notice that was sent to me was on a Friday night which was a holiday weekend and I was out of town and did not return until Tuesday late and read the mail the next day after the meeting took place. E mail may be good if received in a reasonable timely manner but it is not good for a short notice that is intended to provide any industry to give input to pending legislation. This gives the appearance that the agency may not want to hear what we may have to say.
