In a letter to PSSAB Board members issued yesterday by Division Director Gooch, and noted for distribution to interested industry parties, the Department is suggesting as one item the removal of eligibility requirements for compliance agents.  The stated reason is that "the current requirement prevents designation of qualified and or experienced individuals who possess the skills necessary to properly ensure compiance but are not eligible based upon the current limitations of the Code"

I suggest the same situation applies to Certified Training Instructor candidates.  Currently the requirements are quite strict, basically including only those trained by DCJS and those holding State teaching certificates.  Neither requires any industry experience, though the edited regulations do require some subject matter knowledge.  Currently it has been the stated policy of DCJS that any certified training instructor may teach any class by following a filed and approved lesson plan, regardless of the instructor's experience.

I suggest that the language that would "allow businesses to designate compliance agents based on the individuals' education and experience and the changing needs of the industry" perfectly fits the certified training instructor category as well.  DCJS could accept education and experience as qualifications for issuing the certification as training instructor.  This would increase the pool of qualified and experienced instructors and provide better training to registrants.