There are a number of very critical issues with the changes in this proposal. One major problem lies in the requirement for businesses to "ensure that regulated employees of the business have not been convicted or found guilty..." It is, quite simply, impossible to accomplish this. If you enact this regulation, you will be ensuring that all regulated businesses with regulated emplyees are out of compliance from day one. Even if we had access to NCIC to perform daily record searches (which we certainly do not), NCIC does not contain all of the data called for in the regulation, and data is not always entered promptly. There is simply no way to know what employees do on their time off, and no data source in existence that contains the data you're looking for.
     As for the requirement to notify the department of arrests, I am unsure what purpose this is intended to serve. I feel strongly that the department should be doing criminal history checks with every renewal (!), however as we are all still innocent until proven guilty, and an arrest is far from proof of any kind of guilt, I don't see a need for DCJS to be notified in the event of an arrest. If DCJS is proposing to suspend a regulated person in the event of an arrest, I would suggest consulting a lawyer on that.
     Changes to the firearms training and other training-related changes seem poorly-thought-out as well. Particularly at a time when budgets are low and hiring almost non-existent, I would suggest that leaving well enough alone is the right course of action. I urge you to table these proposed changes until you can take the time to really consider their implications, so as to avoid creating a huge problem for all of us--including DCJS.
     I would also urge you to involve private security personnel earlier in the process. I have offered before to help, and I know a great many people in the business who would be quite pleased to be given an opportunity to help make the regulations better and more effective for the industry and for the protection of the people of the Commonwealth of Virginia. Please make use of the tremendous knowledge and talent available to you! Best of luck.