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
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12/12/08  9:53 am
Commenter: Elliott Paul Connor, CML - Top Secret Security

Commentary as pertaining to locksmiths.
 

First of all I would like to say that I was under the impression that this discussion was for comments relating to the new law and how it seems to be working as of now and how it might be improved.  I did not think this was intended to rehash whether the locksmith addendum should have been enacted or not.

 

I am now a DCJS licensed business, as required by October 1, 2008, and as such I believe that I have the right to make the following comments.

 

1.  I find DCJS’s lack of preparedness for dealing with the new category (locksmiths) appalling.  One example is the delay in setting up a search for licensed locksmith businesses.  A second example is the inability to clarify situations (i.e. NSPs) in a quick and efficient manner.  A third example is the lack of appropriate staff.  Calls have gone unanswered and messages left unreturned.

 

2.  A major problem I have with the continuing education requirements is the unwillingness of DCJS to work with national and local locksmith associations in granting approval for their existing training programs and instructors.  These associations have had people and curricula in place for many years and should be utilized; not over looked or even looked down upon for not being DCJS approved already.  Many of these people come from other states and Virginia locksmiths are now being excluded from the benefit of their experience.

 

3.  While the fees did not impact my business profits, I do not feel this license is equal towards all locksmiths.  I do not currently do work for the “general public.”  This term, “general public” should be better defined as well.  I almost deal exclusively with the government and government contractors.  These people know exactly what their requirements are and hire work accordingly.

 

4.  Another concern is the lack of outcry from within the industry.  Since this law is intended to protect the public, what is in place to protect me from the shoddy work being passed off as acceptable by larger companies?

 

5.  The law should encompass all who perform the work as defined.  Just because a company does not need to be licensed, as defined under exclusions, their employees are still performing the work of those that are licensed.

 

Elliott Paul Connor, CML

Certified Master Locksmith

Owner:  Top Secret Security

DCJS: 11-5688

DCJS: 99-216446

 

Memberships:

Safe and Vault Technicians Association

National Safemans Organization

Associated Locksmiths of America

Virginia Locksmiths Association (Vice President & Education Chairman)

Institutional Locksmiths Assocation

 

 

 

CommentID: 6571