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November 4, 2026
Dear Chair Coletta Zapata and Vice Chair Louijeune,
On behalf of the Greater Boston Chamber of Commerce and our 1,200 members, I write to submit comments on Docket #1541, An Ordinance establishing mandatory training requirements for Unarmed Security Guards. The Chamber continues to oppose Docket #1541 and believes that moving forward with a rigid new permitting, training, and enforcement framework will impose unnecessary and extraordinary costs on both the City and employers. As drafted, the proposed ordinance will create unintended consequences for numerous industries and sectors such as healthcare, financial services, hospitality, higher education, commercial real estate, construction, and cultural institutions. Worse, this Docket will potentially upend the security workforce dramatically, increasing the barrier of entry for an increasingly important profession in Boston. We urge the Council to reject the proposed ordinance, or alternatively, significantly rewrite the entirety of the proposal to align with specific public policy goals to provide basic, employer-led standards for unarmed security guards.
As drafted, the ordinance would increase operating costs, reduce workforce availability, and create new administrative burdens for a large share of Boston employers, including many small businesses that rely on unarmed security personnel to support day-to-day operations. It will also inadvertently undermine public safety by reducing the availability of trained personnel and limiting workforce flexibility, all without a clear evidentiary basis for such a significant expansion of regulation. Several provisions of the ordinance raise particular concerns regarding scope, implementation, workforce impacts, and compliance, which are addressed in greater detail below.
Broad Definitions
Addressing the specific language of Docket #1541, the definitions contained in this ordinance are overly broad and could create a duplicative compliance and permitting structure for employers that engage licensed third-party firms to provide security services. For example, the definition of “Security Employer” includes “Any individual, corporation, association, partnership, or business trust, watch, guard or patrol agency as defined in M.G.L. Chapter 147, Section 22, or other business entity, or any group of persons, or a successor thereof, that employs two (2) or more Unarmed Security Guards to perform Security Services at one (1) or more Covered Property,” while the definition of “Employ” or “Hire” includes full-time, part-time, and contracted staff. We respectfully request that the definition of “Security Employer” be narrowed and clarified to ensure that it applies only to entities directly employing or providing unarmed security personnel and does not inadvertently subject businesses that contract with licensed security firms to an additional permitting requirement. A more precise definition would avoid duplicative regulatory obligations for local employers.
Additionally, the threshold of employing “two (2) or more Unarmed Security Guards to perform Security Services…” is simply too low. At that level, the ordinance would capture small businesses, such as stores or restaurants, that may employ only a limited security presence but would be subject to additional and increased workforce costs. Small businesses across industries continue to face significant economic pressure from inflation, tariffs, rising labor costs, and other operating expenses, and will be disproportionally impacted by these additional requirements.
The Chamber also strongly urges the Council to exempt hospitals and other regulated health care facilities from the ordinance. Hospitals operate in uniquely complex, highly regulated environments and
already maintain comprehensive security policies, procedures, and training requirements designed to protect patients, employees, visitors, and health care facilities. These requirements reflect obligations and standards established by state and federal law, regulatory agencies, and health care accreditation bodies. Subjecting our local hospitals to an additional regulatory framework could create duplicative or potentially conflicting requirements without meaningfully advancing public safety objectives. Rather than impose a uniform local framework on institutions already subject to extensive oversight, the City could recognize existing hospital security and training requirements by providing an exemption, or through alternative methods of compliance such as an attestation process.
We also encourage the Council to narrow and clarify the definition of “Unarmed Security Guard” to ensure that the ordinance applies specifically to employees whose primary duties involve providing security services. Without greater precision, the definition could inadvertently encompass cashiers, greeters, information desk employees, and other workers who may perform incidental functions that overlap with security-related activities but are not employed as security professionals. A more targeted definition would provide greater clarity for employers and employees while ensuring that the ordinance remains focused on its intended purpose.
Stringent Training & Certified Providers Requirements
The Chamber remains deeply concerned about the proposed training requirements and whether sufficient training capacity exists to implement them effectively. Requiring every unarmed security guard to complete forty hours of training amounts to a full work week and could create significant scheduling, staffing, and workforce challenges for employers and employees. The ordinance does not establish why forty hours of training is necessary to address specific public safety concerns or why a less burdensome approach would fall short. This mandate could prove particularly challenging for small businesses and security firms operating in a tight labor market, where removing employees from their regular duties for a full week can disrupt operations and increase costs. Without clear justification for such an extensive requirement, the City risks creating new barriers to entering or remaining in the profession without demonstrating a corresponding improvement in public safety.
The Chamber also has concerns about limiting qualifying training to a narrow group of approved providers. Requiring employers to rely on outside providers, including when they already maintain established training programs and experienced personnel, could constrain training capacity and create bottlenecks as thousands of security professionals seek to meet the new requirements. A limited provider network could also drive up the cost of compliance for employers. The City can establish consistent training standards without unnecessarily restricting who may deliver training that meets those standards.
Accordingly, the ordinance should recognize employer-provided training that meets clear and reasonable competency standards. Many employers and security firms already operate robust training programs tailored to their facilities, operations, and security responsibilities. Allowing qualified employer-provided programs to satisfy all the training requirement would build upon these existing investments while expanding training capacity. Rather than prescribing a single training model, the City should focus on establishing appropriate baseline competencies and provide employers flexibility in how they meet them.
Overall, we ask that you and your colleagues continue working with security providers, employers, and other relevant stakeholders to develop reasonable, practical, and achievable training standards for unarmed security guards. Those standards should recognize that security responsibilities vary considerably across workplaces. For example, a security professional working in a large hospital may need different skills and training than a guard stationed in a commercial building lobby. The City should therefore establish clear baseline expectations while allowing sufficient flexibility to address different operating environments and security needs. At the same time, the requirements must remain practical for employers to implement and reasonably attainable for current and prospective employees. An overly prescriptive framework could create unnecessary barriers to employment and make it more difficult for employers to recruit and retain the security professionals they need. A practical, flexible approach can advance the City’s public safety goals while reflecting the realities of the workplaces and workers subject to the ordinance.
Unrealistic Timeline
Simply put, the timeline established by the ordinance is too short and likely impossible for many businesses to meet. While Security Employers would need to apply for a permit beginning with the first July following enactment, all existing unarmed security guards in the City of Boston would have to complete forty hours of training within 180 days of the ordinance’s effective date, which itself begins only 30 days after passage. Newly hired guards would then need to complete the required training within 90 days of hire. We continue to have serious concerns about subjecting employers to significant penalties, including daily fines and potential debarment, before the City establishes a functioning permitting process, a training certification framework, and a fully resourced Office of Labor Compliance and Worker Protections. Imposing enforcement obligations before the supporting infrastructure exists creates substantial compliance risks for employers acting in good faith.
It is difficult to recommend a realistic compliance timeline without a clear understanding of existing and potential training capacity within the City of Boston. The Council should establish training deadlines only after determining that sufficient capacity exists to meet anticipated demand. Similarly, penalties for noncompliance should not take effect until employers have had a reasonable opportunity to access available training and comply with the ordinance’s requirements.
Thank you for your consideration. Please do not hesitate to contact us with any questions.
Sincerely,
James E. Rooney
President & CEO
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