Regarding 6VAC20-171-380. Entry-level shotgun training.

I recommend against this change due to the cost factors and the fact there is no general history in the Private Security Services industry that requires this degree of mandated training. Nothing would prevent private companies from expanding its training to meet a special need.

1.    To be in compliance, everyone having immediate access to a weapon while on duty must have qualified on that weapon.

2.    PSS business personnel may be officially “on duty” while controlling keys to areas where weapons are kept or being in close proximity to such weapons but not be armed security.

3.    Many experienced security officers are highly proficient with a shotgun and able to handle any field incidents but may not be in condition to fire 30 rounds at one time comfortably

4.    Demonstrating proficiency with 5 to 10 rounds on a 12 gauge shotgun to be in compliance is sufficient.

5.    A requirement to fire 30 rounds with a 12 gauge shotgun may be physically unreasonable and could result in noncompliance and/or workmen’s compensation or other claims for possible injuries. 

6.    Dim light/Low light qualification—should be familiarization/practice only—if at all.

7.    PSS officers should not be encouraged to fire in situations where they cannot actually see a threat clearly, especially with a shotgun.  When you make this a qualification it encourages officers to hedge from caution

8.    Mixing weapons such as revolver/shotgun in the same course of fire may not give the desired skill goals for the shotgun user.  

9.    Prolonged shotgun shooting creates the potential for cumulative hearing loss and trauma

10.  Cost factors now with the 5 rounds for qualification: 

*   2 hours plus examination time in the classroom

*   Cost for 1 box of ammunition (5 rounds 00 buckshot) and 1 target

*   range time for setup with one target; actual regulated shooting time totaling 35 seconds; time between two sequences is minimal; scoring one target to determine 75% accuracy (34 out of 45), is about 10-12 minutes

12.  Cost factors with proposed regulations utilizing 30 rounds

*   4 hours plus examination time in the classroom—twice as long

*   Cost for 6 boxes of shotgun ammunition, 3 targets;

*   Range time for setup for 3 targets; actual regulated shooting time of 250 seconds;

*   Range time between 12 sequences and transitions;

*   Time scoring 2 targets to determine 75% accuracy (68 out of 90) on each target

Total comparisons—1/2 minute vs. 4 minutes actual shooting times—8 times as long

*   Setup of 1 vs. 3 targets—3 times as long;

*   Transition time between 2 sequences vs. 12 sequences—6 times as long

*   Time for scoring of 45 maximum hits in one target vs. 180 hits in two—6 times as long

*   Total range time costs times number of students times number of orders—unknown

*   Possible injuries as previously mentioned

Companies that require additional training or standards should be encouraged to do so based on their budget and mission needs, but it is not something that should be mandated for the entire industry.

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