What I like about the proposed regulation changes is that DCJS has listened to some of the changes that were recommended by the industry and put them in there.  The fee changes do not bother me because they were reduced for the most part, but I also feel that some new fees were added just to raise revenues or cover what was cut (for example: an instructor can now pay up to $170 for certification and $150 for renewal if I read this correctly - $50 for initial or $25 for renewal plus $10 for each category and if they are certified to teach all 12 that is 12 X $10).  The changes to the actual regulations regarding schools do not bother me except for the "being arrested" change that is not covered under the Code, which clearly states "convictions".  That change occurs throughout the regulation changes so it is not just applicable to the schools.

 With respect to the schools and instructors:

1.  I am concerned that by taking two hours from the total hours required and dedicating it to a new course - 10E -instructors will be forced to generalize what they can teach as far as the Code and Regs are concerned.  I feel that this will be a detriment since I know many schools tailor this set of instruction to the registration category being taught.  If anything I feel that 2 hours is not enough to teach the Code, and the Regulations, much less having to add private security orientation and the Code of Ethics.

2.  I am concerned with the new "job-related training that includes a maximum of one hour of instruction dedicated to the review of the regulations".  Is DCJS saying that instructors can only teach one hour or are the Code and Regulations also considered to be a part of the legal authority training?

3.  I am concerned with the new 4 hours of continuing education that DCJS has added.  What are the qualifications that DCJS is requiring for it to be valid?   I am not against  instructors keeping up their education but have concerns as to how DCJS is going to enforce this and how they are going to determine if something qualifies since there is no explanation or specifics just a generalized statement.  As we know, different people within DCJS have different interpretations and it needs to be specific enough that everyone, DCJS and the industry are on the same page with no questions.

4.  I am definitely concerned with the new "professional development" requirements.  Who is teaching this? Who determines what is appropriate for this development?  If a training school teaches all of the registration categories that means the instructor has to take 12 different courses for a total of 24 hours plus the four hours of continuing education which equals 28 hours during the certification period.  Where are they going to be able to get that training? What constitutes satisifactory completion for DCJS?  How is DCJS going to verify these new requirements?

5.  What forms are instructors going to have submit for both of these new requirements?  What fees are going to be associated with these submissions.

 I am concerned that changes always seem to be written with generalization. Some of these changes are not specifically defined which leaves things up to interpretation of the individual.  I, and most of the industry that DCJS is supposed to enforce the regulations for, prefer to know exactly what DCJS means and not have to rely on interpretations.  Interpretations that are not uniform throughout DCJS' personnel.  For example: what does "be in possession of" mean?  "Carry" was more definite and easier to understand, so why change it?  Does"be in possession of" just mean that I have to be registered and not have it with me?  Does it mean that I can have in my car that is parked in the parking lot away from my post?  The regulations should clearly define what that means.  The same can be said of "not have an arrest that the prima facie evidence would indicate the propensity for harming the public".  How many lawyers is DCJS regulating?  Over 85% of the industry that DCJS regulates are security officers and I would be surprised if 1% of them have a clue what that means.  This is the same arguement that I have been waging for years with requesting more specific defintions for things like moral turpitude.  Look up the definition for that in Black's Law Dictionary and see if you can tell me specifically what that means.

 Last but not least, we all know that DCJS has had some vacancies and is currently not able to replace those positions.  I and a lot of the industry are concerned with how DCJS is going to be able to enforce all these new regulations.  Strict enforcement of current regulations sometimes seems lacking and adding more regulations to an already over-taxed Department would appear to be burdensome.