Adds another burden to a trainer unnecessarily, increasing continuing education and fees without any benefits.  Being a certified trainer in Virginia has nothing to do with subject matter proficiency.  It is an excessively long and expensive process that again forces industry into supporting a third party business. 

If regulations were clearly written, you wouldn't need a class.  They should be clearly written for anyone in the industry to understand if the goal is compliance.  When you need classes to "understand" what's written, a re-write of the regulation is in order.