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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10/23/12  10:52 am
Commenter: J.C. St. John

Myths, Misconceptions and Misrepresentations About Training
 

Again, specifically as counterpoint to some of the posts made here about training, I'd like to make sure that DCJS isn't fooled by misleading rhetoric and also doesn't think many of the statements made here about training (especially for electronic security or "ES") are representative of everyone out there.

There are several posts specifically referring to DCJS minimum compulsory training for ES.  What comes through loud and clear is that the requirements don't appear to meet the intended result.  And that it's apparently too difficult to submit curriculum to DCJS for approval.  And as I've said elsewhere, if the curriculum isn't adequate, then that's what should be fixed.  You don't throw the baby out with the bathwater.  Yet that's what many of those speaking for the ES community want DCJS to do-- throw out any minimum compulsory training for ES even where the same requirement exists for every other category of private security services....

One comment suggests that getting an ES DCJS registration should be like getting a driver's license-- and then proceeds to misrepresent what getting a driver's license involves. As the DMV points out: "Tests [for a A driver's license] may include a vision screening, a two-part knowledge exam and a road skills test."  Not surprisingly, the reality of getting a driver's license is already similar to the reality of getting a DCJS registration-- if you know what the process actually entails.  What the ES community appears to want, though, is a driver's license that doesn't require them to to take a knowledge exam or a road test.  The public is merely supposed to assume that ES personnel have a minimum level of training even though there would be no standard curriculum, no regulatory oversight of that training, and no minimum standard upon which to measure or evaluate that training.

As a curriculum developer and well-qualified private security services professional who has no personal or financial stake in whether or not ES businesses have to pay for minimum compulsory training, I can state without equivocation that there is a meaningful basic curriculum that could be developed for ES just like those that exist for the several other PSS categories.  The creation of that curriculum may pose a challenge for ES professionals, but it can be done.  Again, though, that minimum compulsory training is not intended to provide all the information a ES tech needs to do their job.  It is not intended to make them experts.  It's just a dissemination of basic knowledge about what regulations they are required to follow and the basics of their category.  Maybe you could give them a pamphlet on it, but that would be like saying that giving people a Rules of the Road Manual is all they need to go out and drive....  Much like Driver's Ed before the test to get a learner's permit or a knowledge exam or road test at the DMV, the DCJS minimum compulsory training and evaluation let's the public know that the person with a DCJS registration card did the minimum required to get a state-issued identification in that category.  There are already plenty of bad drivers on the road.  I can only imagine how much worse it would be if there was no driver's ed, no tests, and no minimum compulsory standards enforced.

Another comment was made about DCJS instructor certification: "[It] 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."  And this is entirely true-- and an entirely irrelevant point in discussing the need for instructor certification.  The instruction and training requirements that DCJS has set up don't differentiate between who is more qualified to teach or between beginners and veterans of the business.  MINIMUM STANDARDS are all the system sets out to establish-- to provide the public with some small degree of confidence and safety.  Of course there are people who have not sought DCJS instructor certification who are well-qualified and well-able to teach on private security topics. 

That's not the point.  

DCJS certifcation provides the public with the knowledge that people who teach others in private security services activities required to be regulated are people who have some minimum level of knowledge about instructing and have had their minimum level of previous experience and credentials vetted by a public servant who is looking out for them.  If you have advanced degrees and decades of documented experience, then I hope that DCJS takes that into account when you ask for a partial training exemption to receive your instructor certification.  But that you're a rocket scientist doesn't mean that everyone who tries to teach DCJS subject-matter is as well.

Regulatory systems like that run by DCJS are mostly necessary because of the weakest-links or the least common denominators.  And that can be frustrating-- especially to those dedicated folks who spend their time to help shape the system for the better-- like those posting comments here.  Unfortuantely, the regulations are necessary to help protect the public from the unscrupulous and unsavory, the miscreants and malign.  MINIMUM STANDARDS can't be enforced without the regulatory structure that's in place.  As such, DCJS should work to fix what's broken-- not throw out the baby with the bathwater. 

CommentID: 24350