Virginia Regulatory Town Hall
Department of Criminal Justice Services
Department of Criminal Justice Services
Regulations Relating to Campus Security Officers [6 VAC 20 ‑ 270]
Action Regulations Relating to Campus Security Officers
Stage Proposed
Comment Period Ended on 10/26/2012


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8/27/12  10:42 am
Commenter: Chief David Carlson, Hollins University Security Department

FEMA/ICS Requirement

Not wanting to delay this process any further, but I would like to comment on the requirement for all CSOs to complete the Introduction to ICS for Higher Ed (IS-100.HE).  

State institutions are required to use the NIMS/ICS system for emergency management, but private institutions are not.  My institution still uses a non-FEMA compliant Emergency Plan and the requirement for my officers to complete IS-100.HE is not cost effective for us (overtime, as the course takes a number of hours to complete and we cannot pull an officer off of patrol for that long a period while on duty).  Maybe the wording can be changed to only be required IF the institution uses the NIMS/ICS system.  Leave it up to the institution to decide like the First Aid requirement.


CommentID: 23815