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                         Quote; “To the extent that this communication may advise you that certain action is lawful, the decision whether to take such action remains a policy decision within the discretion of your agency and this communication should not be construed as a comment for or against the merits of such action.”

 

             The D.C.J.S. has placed the profession of locksmiths into a category of Private Security Service Business which includes things like security canine handlers and a whole host of titles. This agency will require those who have concealed carry permits to be certified by D.C.J.S. which has a very high rate of accidental discharges within its own agencies, to the point they ran out of forms for filing these occurrences. The D.C.J.S. policy along with the terms such as Electronic businesses and a whole slew of categories that absolutely have nothing to do with the locksmith business which I have been involved in for 45 Years.                                                                                                           This agency in its policy making has not considered the Electrical Code of Virginia in its determination that we as locksmiths are in the electronic category of their regulations. Virginia Code allows anyone to use a device known as a low voltage transformer which is plugged into a wall receptacle to be used for the purpose of operating a door bell, electric strikes, magnets, and a host of other items that allow every day people to do what they do without overburdening them with a electrical license or other obstacles that prevent the free flow of business.                                                             What about garage door openers, phone systems, battery powered door locks, Sam’s wholesale sales of camera equipment to the general public that resell it to end users! The definition section of this regulation only defines single words when it suites its own needs and has not define the definition of Electronic.

Under these rules I am not allowed to have school kids who need to work for job training for short periods of time for school credits.

               I am restricted from recommending a business to a customer if they are not certified by D.C.J.S. That sounds like a free speech issue as well as not allowing me to serve my customers best interest.

               In this summary of thoughts and comments the fact remains that Lawyers wrote this law and D.C.J.S. lack of ability to make it clearer to understand. This may also speak to the fact that most locksmiths are of exceptional skills in eye and mind coordination mode and not in tune to the minds of legal types, but having said that most lawyers can not fix a lock. I may be the only one to voice an opinion on this web site because most of the industry is very busy trying to keep their heads above water. In 1994 at public hearing on this subject in the relatively small town of Roanoke VA 39 people from this lock industry showed up to voice their opinions..

 

                I feel the need to try and assist the Board in understanding why I have a strong feeling about the department that has been given the power to enforce this law. I have looked into other states and other trades that have had problems with public fraud and the locksmith is not at the top of the list. I checked with the B.B.B. on two larger lock shops and a one man shop and found that in a three year period there were no Complaints on any of these shops in my area of Roanoke VA.

                The A.L.O.A. is no different than any other association in this country. They do not represent all of their members all the time. In my view this is one of those times.                                                                                                                                                                                                                                                                                                               Their ads placed in major cities around the country that have used the phrase (Phony Locksmiths) have undermined the hard working individuals that perform an honorable service to the public. It would appear that some officials in public office may have let these poor tasting ads influence their judgment.

                There are more general mechanical Locksmiths in the trade than those that perform C.C. TV or Alarm Services to the public and the ones that do perform that type of services are listed with D.C.J.S.

                 Locksmith shops in many areas for example would install electric strikes and magnets for A.D.T. under a subcontract and A.D.T. would do the wiring. Another example is the Locksmith may install an electric strike for a handicap person or secretary in an office using a low volt transformer in a wall receptacle; this type of work is approved by the Code of Virginia.                                                                                D.C.J.S. own web site states under Agency Description: The Department: Distributes federal and state funding to localities, state etc; etc; etc it seems to be obvious that your source of funding is drying up and we have become the States new funding source. The departments filing in 1998 was directed at a reduction in fees for Private Security Services. Now a Locksmith must pay from $ 1,200.00 to $ 1,800.00 depending on how many categories they need to apply for along with hotel, travel, and lost time from work, this is a hardship to small business.                                                                                     I would call that a TAX!                                                                                            

              This law would serve the public best if it had been given to the localities for implementation through their business license department. These localities can do background checks from State Police as well F.B.I They actually can do more than D.C.J.S. because they can speak to local authorities and receive a more direct view of a person character and demeanor .The localities also are better placed and much more convenient for the businesses to receive further Building Code updates. I also can tell you that A.L.O.A. and other sales reps for product knowledge give classes to keep the industry informed of changes.                                                                                                                                                                                                                                                       The State Corporation Commission has in its code for Conduct for Board Members, which addresses their moral and ethical conduct .Do I need another agency telling me how to run my business. The one most important issue in business and life is moral conduct. When Government changes the meaning of words as they have in these regulations, it can cause reasonable persons to perceive that these distortions of the English language is not in the best interest of the same people that it is suppose to protect. It would appear in this case that the end justifies the means.                                                                                                                                                                                                                                                                                Robert Frydrych                                                                                                                       Troutville VA. 24175

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