Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services [6 VAC 20 ‑ 171]
Action Comprehensive Review Private Security Services Regulations
Stage Proposed
Comment Period Ended on 6/10/2010
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4/2/10  6:15 pm
Commenter: Gary P. Bennington

Reg. Issues II -- Continued
 

 

6VAC20-171-300. Private security services training session.
B. Administrative requirements.
3. …The training completion form shall include the following:
B 3 e. An expiration date. Training completion forms SHALL EXPIRE 12 MONTHS from the date of course completion;
Vs
6VAC20-171-360. In-service training.
A. Each person registered with the department as an armed security officer/courier, personal protection specialist, armored car personnel, security canine handler, narcotics detector canine handler, explosives detector canine handler, private investigator, alarm respondent, locksmith, central station dispatcher, electronic security sales representative, electronic security technician, unarmed security officer or electronic security technician's assistant, or certified by the department to act as a compliance agent shall complete the compulsory in-service training standard ONCE DURING EACH 24-MONTH PERIOD OF REGISTRATION OR CERTIFICATION.
In-service training for most registrants (per 171-360-A above) is stated to be accomplished within the 24 months before expiration. Now you propose to limit this by introducing an expiration of the training completion form to 12 months without changing the other regulations. Are you proposing that if a registrant has multiple categories (e.g. Armed Security Officer, PI, and PPS), and all registrations expire at the same time, we will not be able to take ANY in-service training in the first year after the registration expires, and then must take ALL in-service training for all categories in the second year because of the 12 month expiration of “Training completion form”?
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6VAC20-171-350
Part V
Compulsory Minimum Training Standards for Private Security Services Business Personnel Registrations
Article 1
Registration/Certification Registration Category Requirements
6VAC20-171-350. Entry level training.
C. Hour Course and minimum hour requirement. The compulsory minimum entry level training courses and specific minimum hour requirement by category, excluding examinations, practical exercises and range qualification, shall be:
There are NO requirements for “Patrol Rifle”!!
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6VAC20-171-380. Entry-level shotgun training.
A 1 g. Transition from handgun to shotgun/shotgun to handgun (IF APPLICABLE)
What does (IF APPLICABLE) mean, and who determines it?
B. Range qualification (no minimum hours).
1. Fire a minimum of 10 PREQUALIFICATION ROUNDS using 12 gauge, double aught "00" buckshot or rifle slug ammunition and 12 HANDGUN ROUNDS. Prequalification will include transition from handgun to shotgun and shotgun to handgun.
What are prequalification rounds and are they scored?
I only count 6 handgun rounds in the Course of Fire!!
3. Fire 10 rounds of (buck-shot and/or rifled slugs if issued) using B27 single/multiple targets on a NIGHTTIME COURSE with 70% accuracy. 
Also
4. Complete daylight and DIM LIGHT …
I believe you have changed the wording from “nighttime” to “Dim Light/Low Light Qualification” and “dim light” to “Dim Light/Low Light Qualification”.
C. Course: Virginia Private Security Course of Fire for Shotguns.

Prequalification
Condition
Distance
Position
Rounds
Target
Time
Cruiser Safe
15
Standing/shoulder/transition*
3 SG/3 HG
B27
25 SEC
Open breach
15
Kneeling/shoulder
2
B27
15 sec
Cruiser Safe
25
Kneeling/shoulder/transition
3 SG/3 HG
B27
30 SEC

 
The 25 seconds for firing 3 SG/3 HG rounds standing with transition is unreasonable. The current time allowed for shotgun only to fire 3 rounds is 20 seconds, and this is without any transition to a handgun. With the shouldering of the shotgun and transition to handgun, the time should be at least 50 seconds.
The 30 seconds for firing 3 SG/3 HG rounds kneeling with transition is also unreasonable. The current time allowed for shotgun only to fire 3 rounds is 20 seconds, and this is without any transition to a handgun. With the shouldering of the shotgun and transition to handgun, the time should be at least 60 seconds.
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6VAC20-171-395
6VAC20-171-395. Entry-level patrol rifle training. 
What is the category number for Patrol Rifle—Entry level and Re-training (e.g. 08 for Shotgun)
What is the definition of a “Patrol Rifle”?
Semi-auto vs. Bolt Action (e.g. .308 bolt action)? Open metal vs. scoped vs. laser Sights?
C. Patrol rifle qualification course.
1. All rifle qualification will be done with a law-enforcement type and caliber rifle.   A total of 60 ROUNDS of ammunition will be fired for rifle qualification.  
D. Patrol rifle course of fire.
1. …minimum of 30 FAMILIARIZATION ROUNDS …
2. Stage 1 -- 20 ROUNDS
3. Stage 2 -- 15 ROUNDS
4. Stage 3 -- 10 ROUNDS
5. Stage 4 -- 20 ROUNDS
6. Stage 5 -- 5 ROUNDS
E. Low light/dim light qualification course of fire. -- 5 ROUNDS
Actual count in 171-395-D is 105 rounds including the 30 familiarization rounds
CommentID: 13747