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 NOIRA
Comment Period Ended on 12/12/2008
spacer
Previous Comment     Next Comment     Back to List of Comments
12/8/08  10:28 pm
Commenter: Wayne McDonald, The Lock Guy

Locksmith Licensing
 

Where to begin? There are so many issues regarding Locksmith Licensing, that no one response can cover them all.  

1st and foremost: Regarding the issue of licensing: Locksmiths should be licensed BUT not under the dictates of DCJS as Private Security Services Businesses unless any one and everyone that installs and/or services locks is also licensed under DCJS: NO EXCEPTION! This includes ALL contractors, handymen, property manager, facility managers, painters, lawyers, accountants, taxi driver, tow trucks, etc. that install, service or subcontract the installation or service of any kind of locking device for some one else regardless of them calling themselves a LOCKSMITH or not. The primary difference between them and those of us who want to call ourselves locksmiths is that locksmiths specialize in locks and locking devices just like electricians and plumbers specializing in their trades (licensed under the contractor board.) Locksmiths do a BETTER job of selection and installation of locking devices. The law exempts far more people and professions than it includes, but, the exceptions do a disservice to the public as well as those of us that want to call ourselves Locksmiths. I’ve know contractors who subcontracted the lock installation to a painter! I know because I was called in to correct a lock installation: it took me all of 5 minutes to correct the mistake that the painter had spent 4 hours trying to fix.

Since DCJS has exempted all Key Cutters from the licensing requirement and since sales personnel are already exempt by the law, the issue is not the cutting of keys or sales of hardware, what is left to regulate and restrict? What’s left is the installation and servicing of locking hardware and those with the skills to do it best! NOTE: lockouts are a very small part of locksmithing and should be addressed separately. I would gladly give up those few dollars for a proper license and to be licensed by the proper agency such as DPOR and the State Contractors Board.  

How do these functions equate to dog handlers, armored car personnel, private investigators, etc? They simply DON’T! And should not be licensed by the same agency!

Locksmiths cut keys better than any exempt technician! Locksmiths know more about what lock hardware works best in different applications than any exempt sales person! Locksmiths know if a lock is bad or if it is the key that’s bad! Locksmiths know if a lock is of good quality or if it is just the manufacture’s claim that the lock is good quality! These are professional skills that cannot be regulated or imposed by any government agency!

2nd: Virginia is a COMMONWEALTH! The power belongs to the local governments which can better serve the needs of the public! Speaking of the public: where is the public outcry to be protected from the mean and nasty unlicensed locksmiths?

3rd: DCJS stated in its impact statement that it needed to hire 2 additional people to implement the licensing of locksmiths. Virginia has imposed a hiring freeze so DCJS is not able to use the licensing fees to hire and pay these 2 additional people. What is happing to the licensing fees that I and other locksmiths have paid? Looks and smells like a TAX to me!

4th: The locksmith licensing under DCJS is having a negative impact on the citizens of the Great Commonwealth of VA. I’ve heard from numerous locksmiths that they are going out of business because of the cost of licensing. This leaves citizens in rural VA without the services of skilled and experienced locksmiths. Also, I’ve heard from many locksmiths that they have no choice and are raising their prices just to cover the cost of the licensing and registration fees! I know that I’ve had to raise my prices! Thank you Richmond! Who is really being served by higher prices? Not the public! Read on!

5th: HB462 reeks of protectionism for the business owners that introduced and spent so much money to get this licensing law passed. I thought government backed protectionism for businesses was illegal. I’m not a lawyer so it’s just my thought.  

The companies that introduced this licensing law spent years buying out the small locksmiths businesses and lock shops. Why? Was it to control the locksmith industry? They even spent money on a sales rep who tried to get other locksmiths to raise their prices; I know because he told me I needed to raise my prices because I wasn’t charging enough to meet my expensed: If this was true why am I still in business with my low prices.

6th: The training requirement that was stated in HB462 was to be similar to the alarm industry; not identical. If DCJS is going to define and dictate training, why doesn’t it take advantage of its golden opportunity to establish a training syllabus for locksmiths that would benefit locksmiths and the public? Identifying a specific key type is best left up to the employer and provides absolutely no benefit to the public. If DCJS wants to implement useful subjects for training, why not spend the training time teaching “Life Safety”, “Fire Code”, and the state mandated building code standards? I cannot tell you how many times I’ve been called to come and correct the shoddy work of the large locksmith companies when a new business fails its fire and safety inspection!

I attended DCJSs forum on locksmith training and voiced this same suggestion! I was told that the DCJS mandated training needed to make well rounded locksmiths so “they would have skill that would be useful to other employers”. The training was not to make knowledgeable locksmiths or locksmiths that knew anything useful to the public.

7th: As for weapons certification - I know many neighborhoods that I cannot send a lock technician into to provide locksmith services without him being able to carry a concealed weapon. I now avoid those neighborhoods. This is another disservice to the public.

8th: DCJS’s implementation regarding National Service Providers (NSPs) makes it harder for the public to find a simple solution for its general service needs. NSPs provide an easy one stop solution for many of the needs that businesses have in dealing with daily problems that are not related to their business’s function but can impact their daily business operation. Locks are a good example of this. NSPs are not providing the service, they only contact a locksmith and it is the locksmith that is responsible for providing the service and for the quality of the service. NSPs should not be included in any locksmith licensing requirement! NSPs should only be responsible for verifying that the locksmith company they contact is licensed.

This is not the end of the issues I have, but it is all I have time for. If any one at VA Regulation Town Hall wishes to speak to me about these points or others, please call (703) 968-8118.


 

CommentID: 6535