I have several issues with this reg.  Who's paying for this unfunded mandate?  Who is paying for the time and expenses of the instructors who will be required to attain an additional 12-hours of "instructor training?"  As far as the additional instructor training, who is providing that, validating the material of it, and ensuring it's availability?  Oh, wait, AND we have to retest again every two years??  Seriously?  Lastly, why is OEMS considering mandating a requirement on instructors that exists nowhere else in VA's public safety community?  THIS REQUIREMENT IS NOT NEEDED!