PSS Reg Review II

Please consider the following recommendations for incorporation into the proposed Regulations in all sections which apply:

~  Proposed Instructor in-service training requirements are overly-burdensome.  They require an excessive amount of time and money to be used in an ineffectual way.  The current program works.  If there are Instructors who do not comply, standards should be enforced.

~  Lesson plans for training sessions are built on "performance objectives" - the goal of training being competent performance in the workplace.  Several places in the proposed Regs, the term "learning objectives" is used.  It should be replaced.

~ Is an applicant required to submit proof of citizenship or legal resident alien status with an application?

~ What are the definitions of "homeland security" and "documented threat" in 6VAC20-171-190A.4.?

~  PSS registration and certification cards should be issued with photographs which are updated at each renewal to ensure that physical changes are reflected on these identification cards for security purposes.

~  Certification cards should be issued to every compliance agent and instructor certified by the Department indicating the category(s) in which the individual is certified.

~  Please consider requiring Armed Security Officers to carry a less lethal/intermediate weapon when armed.  While there is mention of this as a record requirement, there does not appear to be a stated requirement that each Armed Officer must carry an intermediate weapon while on duty.

~  Training related to PSS-applicable sections of the Code of Virginia and the Regulations Relating to the Private Security Services should not be limited to a specific period of time.  In the lesson plan, the Instructor should  determine how most effectively to present this critical information to a specific category of students -emphasizing the content and practical application most pertinent to keeping them legal and in compliance. This applies to both entry-level and in-service training --  new laws and changes in the Regulations also require presentation and explanation to students.

~  Network Administrator  -  since this person will have access to confidential information regarding PSS personnel, he/she should be required to submit fingerprints for a federal criminal history check.  This would also require legislation.

~  01E - Security Officer Core Subjects and other courses requiring a basic class on "Terrorism" - do not require a specific course such as the cited "Seven Signs of Terrorism"  -  allow the Instructor to utilize resources available to provide the basic information pertinent to Terrorism so that the most current and relevant material will be presented.  Also, Terrorism is not an appropriate part of Orientation - it should be another general subject in the curriculum.

~  Firearms  Training -  the proposed changes to the entry-level and firearms retraining are drastic and would require excessive time and cost.  The current curricula should remain in place.

~  When a registrant is sanctioned with a requirement for remedial training, please add a requirement that the training school and Instructor be notified regarding that student.

~  The Department is proposing additional tasks for staff at a time when positions are being lost or unfilled, resources are lacking, and there would be a need for greater enforcement.  Please reconsider some of these.

                    Thank you for your time and consideration.  I'd be happy to help in any way I can.  I look forward to collaborating with you to develop a comprehensive solution that enables compliance while also mitigating legitimate concerns.

                                                                                                                     Martha M. Clancy