HOUSE OF REPRESENTATIVES STAFF ANALYSIS
BILL #: CS/CS/HB 1233 Online Training for Private Security Officers
SPONSOR(S): Commerce Committee, Regulatory Reform Subcommittee, Fine
TIED BILLS: IDEN./SIM. BILLS: CS/SB 1474
REFERENCE ACTION ANALYST STAFF DIRECTOR or
BUDGET/POLICY CHIEF
1) Regulatory Reform Subcommittee 12 Y, 4 N, As Thompson Anstead
CS
2) Agriculture & Natural Resources Appropriations 14 Y, 0 N White Pigott
Subcommittee
3) Commerce Committee 19 Y, 0 N, As Thompson Hamon
CS
SUMMARY ANALYSIS
The Division of Licensing within the Department of Agriculture and Consumer Services (DACS) is responsible
for the licensure and regulation of private investigation, private security, and recovery services, including Class
“D” unarmed Security Officer and Class “G” Statewide Firearm license applicants.
An applicant for a Class “D” unarmed Security Officer license must submit proof of successful completion of a
minimum of 40 hours of professional training at a Class “DS” Security Officer School or Training Facility
licensed by DACS. A Class “D” Security Officer is not permitted to carry a firearm unless such licensee also
obtains a Class “G” Statewide Firearm license.
An applicant for a Class “G” Statewide Firearm license must satisfy minimum training criteria for firearms
established by DACS rule, including 28 hours of range and classroom training taught and administered by a
Class “K” Firearms Instructor licensee. No more than eight hours of such training may consist of range training.
The bill:
 Allows 20 hours of the 28 hour training requirement for a Class “G” Statewide Firearm license to be
conducted in-person or by live online instruction, with no more than eight hours consisting of in-person
range training which must include safe handling and storage of firearms.
 Allows the 40 hour training requirement for Class “D” Security Officer licensure to be conducted in-
person or online presented live through a secure website of the licensed school or training facility.
 Provides similar reporting requirements for Class "G" Statewide Firearm license applicants and Class
"D" Security Officer applicants who complete their training online, specifically requiring both the
applicant and instructor to submit training results to DACS, and requiring the instructor to provide a
hard copy of the certificate to the applicant.
 Provides that an online training course must: include security questions to ensure the applicant is using
the computer or mobile device; set a minimum amount of time that each applicant must spend on each
screen; maintain a digital attendance log; and include randomized test questions.
The bill requires DACS to adopt rules, including those to establish the online course content, web security
protocols, and course completion reporting requirements.
The bill may have an insignificant negative fiscal impact on the state that can be absorbed within existing
resources.
The bill has an effective date of July 1, 2022.
This docum ent does not reflect the intent or official position of the bill sponsor or House of Representatives .
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 FULL ANALYSIS
I. SUBSTANTIVE ANALYSIS
A. EFFECT OF PROPOSED CHANGES:
Background
The Department of Agriculture and Consumer Services (DACS) supports and promotes Florida
agriculture, protects the environment, safeguards consumers, and ensures the safety and
wholesomeness of food.1 The Division of Licensing (Division) within DACS administers Florida's
concealed weapon licensing program 2 and oversees Florida's private investigative, private security, and
recovery services industries.3 The Division's regulatory oversight of those services includes licensing,
enforcing compliance standards, and ensuring public protection from unethical business practices and
unlicensed activity.4
Private Investigative and Security Services
Currently, the Division offers 22 different types of private investigative, private security, and recovery
services licenses and four different types of concealed weapon or firearm licenses. As of December 31,
2021, the Division had issued a total of 169,758 private investigative, private security, and recovery
services licenses and 2,459,530 concealed weapon permits, to qualified applicants. The following chart
provides a breakdown of the total number of each license type.5
License License Title Total
Type
C Private Investigators 6,992
CC Private Investigator Interns 1,333
A Private Investigative Agencies 2,627
AA Private Investigative Agency Branch Offices 21
MA Private Investigative Agency Managers 81
M Private Investigative/Security Agency 473
Managers
D Security Officers 124,996
B Security Agencies 1,836
BB Security Agency Branch Offices 181
MB Security Managers 1,395
AB Security Agency/Private Investigative Agency 19
Branch Offices
DS Security Officer Schools 378
DI Security Officer Instructors 1,705
G Statewide Firearm Licenses 26,026
K Firearms Instructors 617
E Recovery Agents 743
EE Recovery Agent Interns 282
R Recovery Agencies 282
RR Recovery Agency Branch Offices 38
MR Recovery Agency Managers 1
RS Recovery Agent Schools 6
1 Department of Agriculture and Consumer Services , About, http://www.freshfromflorida.co m/About/ (last visited Mar. 7, 2019).
2 S. 790.06, F.S.
3 Ch. 493, F.S.
4 Office of Program Policy Analysis and Government Accountability, Government Program Summaries, Department of Agriculture
and Consumer Services Licensing, https://oppaga.fl.gov/ProgramSummary/ProgramDetail?programNu mber=4101 (last visited Jan.
23, 2022).
5 The Florida Department of Agriculture and Consumer Services, Division of Licensing Statistical Reports,
https://www.fdacs.gov/Divisions -Offices/Licensing/Statistical-Reports (last visited Jan. 23, 2022).
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 RI Recovery Agent Instructors 9
Subtotal of Private Investigative, Private Security, and 170,041
Recovery Services Licenses
W Concealed Weapon or Firearm 2,445,471
WJ Concealed Weapon or Firearm/Circuit and 809
County Judges
WR Concealed Weapon or Firearm/Retired Law 13,244
Enforcement and Correctional Officers
WS Concealed Weapon or Firearm/Consular 6
Security Official
Subtotal of Concealed Weapon Licenses 2,459,530
Total Number of Licenses 2,629,571
Class “D” Security Officer Licenses
Section 493.6101, F.S., defines the following:
 “Security officer” means any individual who, for consideration, advertises as providing or
performs bodyguard services or otherwise guards persons or property; attempts to prevent theft
or unlawful taking of goods, wares, and merchandise; or attempts to prevent the
misappropriation or concealment of goods, wares or merchandise, money, bonds, stocks,
choses in action, notes, or other documents, papers, and articles of value or procurement of the
return thereof. The term also includes armored car personnel and those personnel engaged in
the transportation of prisoners.6
 “Security agency” means any person who, for consideration, advertises as providing or is
engaged in the business of furnishing security services, armored car services, or transporting
prisoners.
To become an unarmed Security Officer in Florida, a Class “D” Security Officer license is required.7
“Unarmed” means that no firearm shall be carried while providing Security Officer services regulated by
ch. 493, F.S.8 In order to carry a firearm in the course of performing such duties, the licensee must also
obtain a Class “G” Statewide Firearm license in addition to the Class “D” Private Security license.9
To qualify for a Class “D” Private Security license, an applicant must:
 Be at least 18 years old;
 Be one of the following:
o A United States citizen,
o A permanent legal resident, or
o A holder of a work visa from the United States Citizenship and Immigration Service;
 Have no disqualifying criminal history;
 Be of good moral character;
 Have no history of:
o Mental illness,
o Alcohol abuse, or
o Substance abuse;
 Submit an application with certain identifying information;10 and
 Complete 40 hours of required training and submit proof thereof to DACS. 11
Currently, the required training must take place in-person at a licensed school or training facility that
has a physical location.12 Many states, including California and Georgia, do not prohibit online training
for unarmed Security Officers.13
6 S. 493.6101(19), F.S.
7 S. 493.6301(5), F.S. Exceptions to the licensure requirement are listed in s. 493.6102, F.S.
8 S. 493.6101(9), F.S.
9 S. 493.6115(2), F.S.
10 S. 493.6105, F.S. and r. 5N-1.100(6), F.A.C.
11 S. 493.6303(4)(a), F.S.
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 According to the National Conference of State Legislatures (NCSL), 14 11 states do not require a license
for unarmed security guards.15 Of the states that do require a license, 13 do not have any training
requirements in order to qualify for a license,16 and only nine states explicitly require that training be
provided in a classroom setting.17
Class “G” Statewide Firearm Licenses
In order to carry a firearm in the course of duty, the licensee must also obtain a Class “G” Statewide
Firearm license.18 Only Class “C” Private Investigator, Class “CC” Private Investigator Intern, Class “D”
Security Officer, Class “M” Private Investigative/Security Agency Manager, Class “MA” Private
Investigative Agency Manager, or Class “MB” Security Manager licensees are permitted to bear a
firearm and any such licensee who bears a firearm must also have a Statewide Firearm license.19
An applicant for a Class “G” Statewide Firearm license must satisfy minimum training criteria for
firearms established by DACS rule,20 including, but not limited to, 28 hours of in-person range and
classroom training taught and administered by a Class “K” Firearms Instructor licensee. No more than
eight hours of such training may consist of range training.21
Class “DS” Security Officer School and Training Facility Licenses
A Class “DS” Security Officer School and Training Facility license is required for schools and training
facilities that provide training services for Class “D” Security Officer license applicants. An application
for a Class “DS” Security Officer School and Training Facility license must contain the following
information:
 The name and address of the school or training facility,
 The street address of the place where training will be conducted, and
 A copy of the curriculum and final exam to be administered, 22 in accordance with the
requirements set forth by DACS.23
The general content and number of hours of each subject area to be taught in a school or training
facility is established by DACS rule.24 Firearms instructors may use audio/video material as an
instructional aide when teaching the classroom portion of the firearms training course, but a Class “K”
Firearm Instructor cannot rely solely on the use of audio/video material. Firearms instruction must be
presented as live, in-person classes where the firearms instructor is present to allow for necessary
student teacher interaction when teaching students to use firearms.25
Class “K” Firearm Instructor Licenses
12 Ss. 493.6303(4)(a) and 493.6304, F.S.; and Department of Agriculture and Consumer Services , Class "D" Security Officer License
Requirements, https://www.freshfromflorida.com/Business -Services/Private-Security-Licenses/Class-D-Security-Officer-License-
Requirements (last visited Jan. 24, 2022).
13 Cal. Bus. & Prof. § 7583.6 (2017); Ga. Comp. R. & Regs. r. 509-3-.02; and O.C.G.A. § 43-38-7.1(a).
14 Email from Zach Hermann, MSW, Research Analyst II, Employment, Labor & Retirement Program, National Conference of State
Legislatures, NCSL REPLY: classroom vs online education for unarmed security guard licensure , (Mar. 11, 2019).
15 Colorado, Idaho, Kansas, Kentucky, Massachusetts, Mississippi, Missouri, Nebraska, Rhode Island, South Dakota, and Wyoming.
16 Indiana, Iowa, Maine, Maryland, Michigan, Montana, Nevada, New Hampshire, Ohio, Pennsylvania, Texas, West Virginia, and
Wisconsin.
17 Alabama, Georgia, Illinois, North Carolina, North Dakota, Oregon, Utah, Vermont, and Virginia.
18 S. 493.6115(2), F.S.
19 S. 493.6115(2), F.S.
20 R. 1.132, F.A.C.
21 S. 493.6105(5), F.S.
22 S. 493.6304, F.S.
23 R. 5N-1.134, F.A.C.
24 S. 493.6303(4)(a), F.S.
25 R. 5N-1.132(4)(c), F.A.C.
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 A “firearm instructor” is defined to mean any Class “K” licensee who provides classroom or range
instruction to applicants for a Class “G” Statewide Firearm license.26
To qualify for a Class “K” Firearm Instructor license, an applicant must comply with the age, citizenship,
criminal and mental history, and other general requirements in the section of law governing the initial
application for private investigative, private security, and repossession services licensees.27
In addition, an applicant for a Class “K” Firearm Instructor license must:28
 Submit one of the following:
o The Florida Criminal Justice Standards and Training Commission Instructor Certificate
and written confirmation by the commission that the applicant possesses an active
firearms certification.
o A valid National Rifle Association Private Security Firearm Instructor Certificate issued
not more than three years before the submission of the applicant’s Class “K” application.
o A valid firearms instructor certificate issued by a federal law enforcement agency issued
not more than three years before the submission of the applicant’s Class “K” application.
 Pay the fee and pass the examination administered by DACS, which is based upon, but not
necessarily limited to, a firearms instruction manual provided by DACS.
Class “K” Firearm Instructor licensees provide classroom or range instruction to applicants for a Class
“G” Statewide Firearm license.29 Class “K” Firearm Instructors are not currently required to be affiliated
with a school or training facility. Adm