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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10/22/12  9:06 am
Commenter: Wayne Boggs, Richmond Alarm Company

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Mr. St. John notes that "instructors are required to be certified by DCJS to ensure that a minimum standard is met by those who provide training on regulated activities".  My experience has been that the DCJS certification does not and cannot guarantee that the individual who passes the DCJS class is any more qualified to teach an electronic security subject than someone who has spent years in the industry.  In my own case I hold a BS degree in Physics and Mathematics and an MBA degree in Business, both from Universities in the Commonwealth.  I also hold instructor certification by the national trade association representing the electronic security industry, and have taught numerous classes on a national level, as well as having over 30 years of experience in all levels of operations and management, but I am not considered qualified to teach a class on any subject.  I can however become qualified by attending a 5 day training session conducted by DCJS.

I also disagree on the matter of training content.  Security system design and installation techniques are constantly evolving.  We rarely spend hours running wires in walls in homes or businesses with the current technology in wireless systems.  National companies like Verizon, Comcast, Vivant, and ADT, no longer lead their sales presentation or marketing efforts with security systems.  Today everything is home automation, temperature control, lighting, locks and video.  None of these services were even available one year ago.  Comcast and Vivant have both stated that they expect electronic security to be a decreasing part of their offerings over time.  We still expect centrally monitored security systems to be a large part of the business on a local level for many years, but we are adding many more centrally monitored or managed services as well.  To provide entry level training for salespeople and technicians on even two year old security technology does not prepare them to provide current technological services to prospects, nor in any way assure the safety of the public.

I also operate a U. L. listed monitoring center, and we send our operators to basic entry level training classes from licensed training schools simply to meet the requirements of the law.  We then spend the next two weeks training them on false alarm prevention, customer service, and technology.  These subjects have not changed much in recent years, but the additional tasks of managing video and access control systems and answering the myriad of technical questions they are asked at all hours by concerned clients whose security and fire alarm systems are malfunctioning, takes months more.  Ask a central station operator if they need technical training on security systems in order to competently perform their duties.  They will certainly laugh at the idea that they are not providing technical services.

Regarding salespeople and technical training, just in the area of video equipment, within two years the conventional analog camera systems that have been in use for the past 20 years will not longer be available.  Digital technology, particularly IP technology is sweeping the industry.  We don't even attempt to maintain printed catalogs or price lists any more; the products, their applications, pricing and features are changing so rapidly.  Basic sales techniques remain the same, but the technical application of the available products simply outstrips the ability of any for-profit school to adapt.

Finally, the marketplace is the final arbitor of who is qualified to provide a product or service.  Any business who does not regularly train their employees on the latest technology will find ever vanishing prospects.  Prospects will ask questions they cannot answer and demand products and services they don't understand.  DCJS and the licensed training school simply cannot react with the speed of the marketplace.  Certainly members of the public will be offered lower quality services by unqualified providers, but not likely on a widespread basis.  The proliferation of comparison and evaluation sites such as Angie's List and the Better Business Bureau, and the power of social media provide ample opportunity for the public to find appropriate information prior to making a purchase.  If a firm misleads the public, DCJS should investigate and sanction.  In recent years the vast majority of problems have been with unethical operators whose personnel meet the basic training requirements.  It is simply not possible to mandate a level of ethics and proficiency that assures the public will always receive the service they expect.  Rather than waste money on training that satisfies no one but DCJS, let businesses spend that money on training that is useful and productive.

CommentID: 24325