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9. Please describe the extent to which the rules conflict with or duplicate similar rules,
compliance requirements, or other standards adopted at the state, regional, or federal level.
The rules do not conflict with nor duplicate similar rules, compliance requirements, or other standards
adopted at the state, regional, or federal level.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
list/cscl/licensing/prof/alarm) features under the header “Quick Links”, links and instructions to obtain,
renew, and verify a license and links to relevant statutes and existing rules. The link to obtain a
license is labelled “MiCLEAR – Licensing – Apply/Renew”. To verify a license, there is a link labeled
“Verify a License”.
Under the header, “Licensee Information” there is a link to “Uniform and Insignia Requirements,”
which lays out general instructions for licensees to comply with section 19 of the act. Under the
header, “Spotlight,” there are informational documents to assist applicants and licensees with general
questions.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed for
the current year?
No.
12. Will the proposed rules be promulgated under Section 44 of the administrative procedures act
of 1969, 1969 PA 306, MCL 24.244, or under the full rulemaking process?
Full Process
13. Please describe the extent to which the rules exceed similar regulations, compliance
requirements, or other standards adopted at the state, regional, or federal level.
The rules do not exceed similar regulations, compliance requirements, or other standards adopted at
the state, regional, or federal level.
14. Do the rules incorporate the recommendations received from the public regarding any
complaints or comments regarding the rules? If yes, please explain.
Yes. CSCL has received since 2014, numerous public complaints regarding private security guard
agencies licensed under 1968 PA 330. These complaints concerned subcontracted agencies,
uniforms and patches of guards, and advertising. The problems that these rules aim to address were
informed in part by these complaints by the public.
15. If amending an existing rule set, please provide the date of the last evaluation of the rules and
the degree, if any, to which technology, economic conditions, or other factors have changed
the regulatory activity covered by the rules since the last evaluation.
R 28.4001 through R 28.4007 were rescinded in 2014 and no new rules have been evaluated or
written since then. In that time, the department has encountered difficulty enforcing certain provisions
in 1968 PA 330 because the previous rules had provided the clarity necessary to do so. For instance,
the specifics about which words may be used in agency names and determining which individual
oversees daily operations. Without the rules in place, applicants and licensees have been confused
about how to comply with statute when it comes to uniform and badge requirements and names and
emblems in advertising.
As to economic conditions, since 2014, the private security guard and security alarm contractor
industry has grown in the state, as has the use of subcontractors within the industry. The industry is
projected to have continued growth through 2030 according to some studies (Private Security Market
Size, Share | Industry Growth [2030] (fortunebusinessinsights.com)).
16. Are there any changes or developments since implementation that demonstrate there is no
continued need for the rules, or any portion of the rules?
No.
17. Is there an applicable decision record (as defined in MCL 24.203(6) and required by MCL
24.239(2))? If so, please attach the decision record.
MCL 24.239