Section 150 says that the board must approve all training.  Course information must be submitted 45 days prior for the board to consider it.   I think course approval will occur on the whims and desires of the board membership.  In other words, it will be an arbitrary process.  I would prefer the board not having to worry if  a specific piece of training (and the trainer) is going to be appropriate.  Instead, the board should accept continuing education that a college confirms is appropriate for continuing education and place clear directives in the regulations.  All training should not have to be approved by the board. 

The proposed regulations should clearly define what is acceptable and not instead of making organizations have to come to the board 45 days before the training course.  My experience as a member of VEHA, VOWRA, VAPSS, & other professional organizations, I think these groups may find it difficult to submit course approval and instructors to the board at least 45 days before the event.  Why does the board need so much time?  Why can't they review it after the training event takes place?  If the board is following a consistent and fair process of evaluation, it shouldn't matter when they review the course for approval.

Instead of the board trying to figure out who is qualified to train and who is not, make the rules such that it is very clear what the board expects so people don't have to fear the whims of the board's membership.