Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Special Conservator of the Peace [6 VAC 20 ‑ 230]
Action Comprehensive Review and Update of the Training Standards Relating to Special Conservators of the Peace
Stage NOIRA
Comment Period Ended on 3/2/2022
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2/24/22  1:17 pm
Commenter: Charles Law, Dept of Behavioral Health and Developmental Services

Comments on enhanced training requirements for SCOP
 

The Dept of Behavioral Health utilizes a hybrid approach to security and law enforcement on our facility campuses.  We partner with the VSP, local law enforcement, employ SCOP and security staff as well as embedded hybrid care/security staff into each patient area.

We operate a DCJS Certified Training Academy to assure our staff are trained to the highest standards and in a quality manner across our system using DCJS audited materials and policy.

To dramatically increase training requirements adds time which will equate to more positions to train our systems staff, it adds days of travel to our centralized training academy and a plethora of small costs.  As mentioned by other state agencies, our jobs in state agencies is not to be a "street cop".  In our case, its patient care - the safety of individuals committed to state hospitals and training centers.  We also have a dual mission to protect our staff from workplace violence.  We call in the most skilled units of VSP and a nationally certified local law enforcement partner when the "right tool" is needed to perform those extreme risk duties.  We have an excellent relationship with law enforcement professionals to handle the toughest and most dangerous situations like active shooter, etc.

We will follow the regulations if adopted, and we will perform them to the letter.  However, is this action evoking the intended results or is it innocently adding burdens to partner agencies across the Commonwealth in a manner bringing unintended cost and consequences?

CommentID: 120179