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 10/24/2012
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10/19/12  12:47 pm
Commenter: Wayne Boggs, Richmond Alarm Company

Allow Companies to Conduct their own training
 

Currently all training must be conducted by a licensed training school, using DCJS registered instructors.  Since the electronic security industry is highly technical and that technology is constantly changing, it is impossible for training schools to provide training classes that keep current with technology.  Current DCJS policy requires training schools to allow 60 days for lesson plans to be approved.  The cost of lesson plan design and documentation and the time delay between submission and training precludes training schools from conducting training that addresses current technology and processes.  Most manufacturers update their equipment line at least twice a year, and offer regular training to their clients.  This training is not acceptible to DCJS since the documentation is not submissible in strict cirriculum lesson plan format.  These classes must change regularly in order to maintain currency, and to constantly update such plans is economically unfeasible.

Most electronic security firms depend on manufacturer provided training to keep their salespeople and technicians up to date, but under the current system cannot apply this regular training to their registration requirements.  This requires them to spend additional time with a licensed training school receiving training that satisfies regulatory requirements but not real world business requirements.

The only answer is to allow employers to do their own training on subjects of their choosing with instructors of their choosing and have a system in place to allow them to submit training information easily and quickly.  Ideally training should be provided by qualified company employees or factory representives, without requiring DCJS instructors.

The current waiver program is now working for electronic security since DCJS does not readily approve such training, and requires far more documentation than is generally available.  

 

CommentID: 24308