I am all for regulated training requirements, but I don't think the DCJS
really understands why or when it's appropriate. I have experienced regulated
training requirements in 4 different areas: as an OSHA certified trainer, as
a Central Station Operator, through observing the training required for
certified electricians, and through extensive experience with my father's
Virginia based defensive driving school.

In the case of OSHA certified trainer and certified electricians, the
training involves a very thick manual of regulations, which is necessarily
updated yearly. However, the training does not involve making trainees
memorize every regulation in the book. The training helps them to understand
how the regulations are categorized, and how to use the manuals to look up
the information they need. To make them memorize every regulation would be
impossible, and pointless. Memorization of key regulations comes with
repetitive use in the everyday work. Anything else is on an "as needed"
basis, and that's where knowing how to use the manuals comes into play.
 

For a defensive driving school, the class training is necessarily regulated
by DMV and the National Safety Council, and focuses on practical instruction
for safe driving. In this situation, it is necessary for the trainee to come
to the classroom, because the 8-hour training is for individual drivers from
all walks of life, not for a specific field or industry. Although the
circumstances bringing each driver to the class are different, the training
is the same, and the certificate received at the end of the class serves to
tell the court that the trainee has passed a test that reflects their
understanding of that information.

This is in no way how DCJS "training" works. To get my Private Security
Services Registration, I had to take an 8-hour class. The class spent a great
deal of time laboring on the authority/reporting structure of the DCJS board,
on requirements for installers, on how the DCJS numbers are set up, and other
minutiae that had practically nothing to do with being a CS Operator. The
information given in the 8-hour class isn't practical for anything to do with
the registration card, and having the registration card does nothing to
guarantee that I have learned how to be a CS Operator.
 

The training that was essential to my job was handled on-the-job, over a five
week period, and covered a wide variety of alarm types and alarm
instructions. I had received this training well before I had the 8-hour
class, so the little bit of the class that was relevant to my job, I had
already been trained on. The rest of the 8-hour class - info on the DCJS
board, DCJS numbers and such - could be printed in a standard booklet that
one receives with their DCJS PSS Registration card. The cardholder would then
be responsible for reading this booklet on their own, the same way a driver
is responsible for reading their driving manual.

The only thing a DCJS PSS Registration card should be good for is
guaranteeing any prospective employer that from the Issue Date to the
Expiration Date, I have had a proper background check, and been deemed
eligible to work in the Private Security Services industry. Therefore, the
class is not necessary for the card. What is necessary is a set of
fingerprints, a background check, and a picture. This could all be obtained
in a process similar to getting your driver's license at a DMV. Instead, my
employer handled the fingerprints and submitting my info for a background
check, and my picture was taken at my 8-hour class. I still had to go stand
in a DMV-like line (although it was nowhere near as efficient) at the DCJS
office, to pick up my card, which should have been mailed to me.

Although my PSS Registration card can travel with me from job-to-job, the
practical training does not, so requiring businesses to send their employees
for centralized training isn't practical. Much like OSHA training, any new
company I go to is going to have to train me agaim, strictly for liability
reasons: they cannot be sure that I receieved adequate training at my
previous company, so they must train me again to their standards. The
training received in the 8-hour class does not apply.