After reviewing the proposed changes to 6 VAC 20-171, I want to provide the following comments:

6 VAC 20-171-10 Definitions.  Include a definition of "Related Field" as it is used in determining qualifications for business licenses, compliance agent certification, etc.  In the definition, it would be useful for the department to identify several examples of just what a "related field" is.  More examples would be better than few examples.

6 VAC 20-171-20D Adds a $20.00 fee to applications not made on line.  Someone needs to tell registrants that they need to sign up for WATSON on line.  Perhaps it would be nice if DCJS automatically provided new registrants with a WATSON pin when they become registered and get their temporary authorization letter.  Also include the reason that WATSON is a good idea to learn and use.

6 VAC 20-171-30 Fingerprints.  If an applicant has committed a criminal offense they must complete the criminal history form and return it with the fingerprint processing application.  Given that many potential registrants do not have funds they can afford to spend in the hopes that their criminal convictions do not disqualify them, it would be useful for DCJS to establish a process by which applicants may provide information to the department and determine if their criminal conviction will disqualify them before they send the non-refundable fee to the department.  Email would work.

6 VAC 20-171-170 - The title still reflects use of the term "Letter" when that term is lined through below and "Card" is used to replace it.  Consistency suggests that "letter" be dropped and card used instead throughout the text.

Addition of "10E" instruction.  The proposed 2 hours for DCJS regulation indoctrination and education is a good idea, but,  2 hours is too short to adequately cover the material.  I suggest 4 hours. The idea is great to have a one time course covering the regulations, but for schools to teach it in the classroom, I'm not sure that is will be practical.  On-line instruction for this subject provided by DCJS would be more suitable and make it easier on students and schools as far as completion and scheduling.  Have the course on-line, students complete it and print the certification of completion, bring it to the school where they attend their training and it's done.