Retaining Law Enforcement Volunteers Under SB 1454

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Charlie Cutler

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California churches cherish the expertise of active-duty and retired law enforcement officers on their security teams. However, Senate Bill 1454 (SB 1454), effective January 1, 2025, requires these volunteers to comply with strict Bureau of Security and Investigative Services (BSIS) rules, including oversight by a licensed Private Patrol Operator (PPO). Many officers may resist these mandates, viewing them as redundant to their Peace Officer Standards and Training (POST). Without action, churches risk losing these skilled volunteers or facing penalties. Here’s how to retain your law enforcement officers while staying compliant.

Why SB 1454 Affects Law Enforcement Volunteers

SB 1454 eliminated exemptions for churches, mandating that anyone performing private security duties—protecting people, property, or preventing theft—complies with the Private Security Services Act (Business & Professions Code § 7582.1). This includes officers acting as armed or uniformed security, whether paid or volunteer.

Key Requirements:

  • BSIS Firearms Permit: For exposed firearms, requiring a psychological assessment, written exam, and POST certification (waives 8-hour firearms training).
  • Security Guard Registration (Guard Card): For security duties, involving 8 hours of initial training (Power to Arrest and Use of Force) and 32 hours of continuing education. POST records may waive some training.
  • PPO Oversight: Officers must work under a BSIS-licensed PPO, which ensures compliance, maintains $1 million liability insurance, and reports to BSIS.

The Law Enforcement Officers Safety Act (LEOSA) allows concealed carry but does not exempt officers from SB 1454’s private security rules. The case Woods v. American Film Institute (2021) confirmed that functions, not titles, trigger compliance.

The Challenge: Officer Resistance

Officers often balk at BSIS and PPO requirements for volunteer roles due to:

  • Time and Cost: Guard cards require 40 hours of training, ~$104 in fees, and $40 biennial renewals. Firearms Permits add ~$100 plus assessments.
  • Redundancy: POST training surpasses BSIS’s 8-hour courses, making compliance seem unnecessary.
  • PPO Affiliation: Working under a PPO adds oversight that officers may view as bureaucratic.
  • Liability Concerns: Officers may avoid private security roles to limit personal risk or agency conflicts.

Non-compliance risks $5,000 fines per violation (Business & Professions Code § 7587.1), lawsuits, or insurance denials—threatening your church’s safety and mission.

Solutions to Retain Law Enforcement Volunteers

  1. Partner with a Faith-Focused PPO
    Collaborate with a PPO like Shepherd 360, which oversees officers, handles BSIS compliance, and employs or integrates volunteers via HALO Certification. This reduces administrative burden while keeping your team compliant.
  2. Leverage POST Waivers
    Officers can submit POST records to waive guard card training components (e.g., Power to Arrest). ChurchWest can streamline this process.
  3. Contract On-Duty Officers
    Hire officers through police departments for official duties, bypassing BSIS and PPO rules. This ensures compliance but may cost $20,000–$50,000 annually.
  4. Limit to Concealed Carry
    Allow officers to carry under LEOSA/CCW without performing security duties. This avoids BSIS oversight but limits their role.
  5. Advocate for BSIS Clarity
    Push for streamlined exemptions. Current vague guidance (e.g., March 2025 Christian Warrior Training) frustrates compliance. Work with networks to encourage clearer rules for officers.

Steps to Take Now

  1. Identify officers performing security duties.
  2. Verify BSIS permits, guard cards, and PPO affiliation.
  3. Contact Shepherd 360 or other PPOs for officer integration.
  4. Store compliance documents in your SB 1454 binder.
  5. Schedule a free ChurchWest Compliance Check.

Protect Your Team and Mission

Losing law enforcement volunteers weakens safety. Non-compliance could cost $5,000 per violation or void insurance coverage. Retain your officers with PPO partnerships and proactive planning.

👉 Contact ChurchWest for compliance resources or read our Ultimate Guide to Ministry Security. Subscribe for Q4 2025 vendor updates.

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Charlie Cutler

Charlie Cutler is the President of ChurchWest Insurance Services, a California-based agency that specializes in providing insurance solutions to churches and related ministries. Charlie has been with ChurchWest for over 20 years and has extensive experience in the insurance industry, with a particular focus on the unique risks and challenges facing Christian organizations. Charlie is a sought-after speaker and has presented at numerous conferences and seminars on insurance and risk management topics.

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