Please consider the following general recommendations for incorporation into the proposed Regulations in all sections which apply:

  >  There is not legal authorization in the Code, Section 9.1-139K, to require notification of arrests.  It authorizes notification of convictions. 

  >  There is no procedure for the submission of training completion rosters to the Department by schools.  This signals a major change in priorities and undermines the importance of training in the regulatory process.  The files maintained by DCJS must include individual training records as these are integral to the determination of the person's fitness for duty and the basis for approval of the issuance of a registration or certification.  While the Department seeks to add additional duties and tasks for its staff in these proposed Regulations, eliminating basic functions is not the means to accomplish that.

  >   Proposed Instructor in-service training requirements are overly-burdensome - they require an excessive amount of time and money to be used in an ineffectual way.  The current program works.  If there are Instructors who do not comply, standards should be enforced. 

  >  DCJS registration, certification, and firearms endorsement cards should be issued with photographs which are updated for each renewal to ensure that physical changes are reflected on identification cards for security reasons.

  >  "Certification identification cards" should be issued to every compliance agent and instructor certified by the Department indicating the category(s) in which the individual is certified.

  >  Please consider requiring Armed Security Officers to carry a less lethal/intermediate weapon when armed. While there is mention of this as a record requirement, there does not seem to be a stated requirement that each Armed Officer must have an intermediate weapon.

  >  Lesson plans for training sessions are built on "performance objectives" - the goal of training being competent performance in the workplace.  Several places in the proposed regs, the term learning objectives is used.  It should be replaced.

  >  It is not possible for a business or its employees to "ensure" that individuals have not been convicted of a crime.  That would take access to criminal history record information that is accurate and current.  The only true source of such information is the NCIC - no private source is available to the public by law.  By issuing a license, registration, or certification, the Department acknowledges that the person meets the criminal history standards.  Delete this requirement.  It cannot be met by the empoyer and is therefore unreasonable.