How to Prepare for Philadelphia’s New Employer Training Obligations for Security Officers While Enforcement Remains Postponed

Earlier this year Philadelphia enacted an ordinance, Phila. Code, Chapter 9-6800 - Minimum Training for Security Officers, to address public safety and workplace violence threats, avoid the use of excessive force, and ensure that security guards are provided with the skills to safeguard themselves and the public. The new law requires nearly all employers of security guards within the City of Philadelphia to ensure that security guards complete interactive mandatory training provided by a Recognized Security Training Program, and pay for the time and expense of doing so. Most in-house training programs will not meet the requirements to be certified as a Recognized Security Training Program, because they will not have a track record of providing such training for five years.      

Although the law became effective on March 1, 2026, implementation and enforcement of the law have been postponed until the Philadelphia Department of Labor’s Office of Worker Protections (OWP) establishes criteria and an application process to have a training program be certified as a Recognized Security Training Program, and then publishes a list of Recognized Security Training Programs. Because the law places the burden and cost of compliance entirely on employers of security guards, this article summarizes its provisions and provides practical guidance on how to prepare.   

Coverage 

The law covers all security guards working in the City of Philadelphia, except for law enforcement officers, armed security guards, and security guards working at nightclubs and similar locations who are already covered by mandatory bouncer training. The following definitions establish the broad coverage of the law:    

• Security Employer is any individual, business entity, or group of persons that employs a Security Employee to provide Security Services at a Covered Property within the City of Philadelphia. 
• Security Employees include any persons primarily employed to perform Security Services at a Covered Property as an employee, agency or subcontractor of a Security Employer, except for city, county, state, federal, or local law enforcement officers or any person licensed and trained in the use of firearms for private security purposes (i.e., under the Pennsylvania Lethal Weapons Training Act (“Act 235”), 22 P.S. §41 et seq.). 
• Security Services include the protection of individuals or property from harm or unlawful or unauthorized activity or the deterrence, observation, detection and/or reporting of incidents to prevent or abate any harmful, unlawful or unauthorized activity. 
• Covered Property includes any parcel of land or other real estate where a Security Employee is employed, except for locations already covered by mandatory bouncer training under Phila. Code, Chpt. 9-3700 (nightclubs, discotheques and cabarets; taverns and bars; restaurants with 30 seats or more; private clubs; banquet halls; and similar places of assembly without primarily fixed seating).

Mandatory New Hire and Annual Training for Security Employees 

The law puts the burden and cost of mandatory training compliance entirely on Security Employers, who (1) cannot employ Security Employees at a Covered Property unless they receive the mandatory training; (2) must pay for the cost of training and the time spent in training at the regular hourly rate of pay; (3) cannot require a Security Employee to possess a certification of the training as a condition of hire; and (4) cannot charge a Security Employee a fee for a training certification. 

• New Hire Training. The mandatory training includes at least 12 hours of new hire training, and at least 24 hours of new hire training for security guards employed at a college, university or hospital, within 90 days of hire for those hired after the effective date of the law (still postponed), unless the Security Employee was employed as a police officer within three years immediately preceding their employment and provides supporting documentation to showing this. 
• Annual Training. At least eight hours of training during each 12-month period following the date of completion of the new hire training. 

Requirements to Be Designated a Recognized Security Training Program

The law sets forth the following minimum qualifications to be designated by the OWP to be a Recognized Security Training Program. 

1. Program Owner/Operator. The Program must be owned or operated by a non-profit entity or a Security Employer.
2. Training Experience. The Program must have at least five years of experience providing training related to Security Services. 
3. Mandatory Training Topics. The Program must provide interactive training on at least the following mandatory topics: (a) the appropriate use of force and alternatives to use of force; (b) first aid, cardiopulmonary resuscitation (CPR) and use of automated external defibrillators (AEDs); (c) an orientation to the security industry, including industry standards for reporting incidents and preparing written incident reports; (d) the legal powers and limitations of a security officer; (e) effective communication and writing skills; (f) emergency response and communication procedures; (g) security officers’ workplace rights, including health and safety, anti-discrimination, and wage and hour laws; and (h) additional topics including those required by applicable law and regulation for colleges, universities and hospitals.
4. Interactive Instruction. The Program must provide training exclusively through interactive instruction that “actively engages learners through in-person or technology-based methods designed to foster deeper understanding and retention of material, such as: scenario-based exercises and branching logic; drag-and-drop or click-to-reveal activities; embedded knowledge checks and quizzes with immediate feedback; multimedia content that requires learner action to advance; controls that prevent fast-forwarding or skipping; automated session time-outs after a period of inactivity; and a Learning Management System (LMS)-based tracking of learner progress, quiz results, and course completion.” 
5. Dispute Resolution Process for Programs Offered by Security Employers. If the Program is offered by the Security Employer, the Security Employer must have a dispute resolution process to resolve complaints regarding compliance with the law, unless there is an established dispute resolution process through collective bargaining. The dispute resolution process must: (a) be with the employee, the employer and an independent party; (b) be free and include all remedies available under the law and a binding appeal to a neutral third-party decision-maker; and (c) prohibit retaliation for using the process. The Security Employer must notify all employees of their rights to dispute resolution and how to access the process, which must be posted in all work locations or posted electronically for all employees to access.  
6. Completion of Application Process. The Program must pay application fees and submit an application providing the identity and qualifications of the security training program’s owners, program director and instructors (who must meet minimum education and experience requirements); a chronological listing of curriculum topics specifying the content and duration; an affirmation that the owners and the program director are not delinquent with respect to any City tax, fine or fee; and proof of liability, workers’ compensation and other insurance in amounts specified by the agency.  

Training Certifications, Recordkeeping and Annual Reporting to OWP 

Upon the satisfactory completion of mandatory new hire or annual security training, the Recognized Security Training Program must issue a written Certification of Training in a form specified by the OWP to the Security Employee, the Security Employer, and the OWP. Recognized Security Training Programs must update the OWP on their qualifications annually. 

Security Employers are required to keep records documenting training received by Security Employees, including wage records and payments of training fees and costs, for at least three years, which must be produced to the OWP upon request. Security Employers will be required to submit annual reports on July 1 listing all Security Employees employed at any Covered Property during the prior 12 months and their hire dates, the new hire and annual trainings completed, the identity of the Recognized Security Training Program, and a description of the training. 

Notice of Rights and Prohibited Retaliation 

The OWP will provide a Notice of Rights that must be posted in a conspicuous and accessible place on the employer premises where notices to Security Employees and applicants for employment are customarily posted, or electronically in a manner that is accessible to all employees. 

Security Employers are prohibited from taking any adverse action against any individual for the good-faith exercise of their rights under the law including: the right to receive free training, to be paid the regular rate of pay for training time, to receive a Certification of Training upon completion of the training program, to file a complaint for alleged violation of the law, to cooperate in an OWP investigation, and/or to inform any person of their potential rights under this Chapter. There is a “rebuttable presumption” of retaliation for adverse employment action occurring within 90 calendar days of protected activity; however, this presumption may not apply if the Security Employer has established comparable rights and remedies in a collective bargaining with a grievance and binding arbitration process. 

Enforcement and Penalties

Security Employees or their collective bargaining representatives may (1) report violations of the law to the OWP, which are punishable by a $500 fine per Security Employee per instance / basis for each violation, or (2) in the absence of a collective bargaining agreement with a grievance and binding arbitration process, may file a civil action seeking legal or equitable relief to remedy the violation, plus reasonable attorney’s fees and costs. Repeat and/or severe violations may be punishable by debarment after a 90-day cure period, as per the procedures set forth in Phila. Code §9-103. 

Practical Guidance on How to Prepare

Any entity that employs security guards at locations in Philadelphia should evaluate the pros and cons of applying to be a provider of a Recognized Security Training Program, and whether to (a) apply themselves, (b) engage a nonprofit provider to provide the training to their Security Employees, or (c) outsource security guard services to a Security Employer responsible for providing the training, keeping in mind the notice and retention rights provided by the Protection of Displaced Service Employees law, Phila. Code §9-2300. 

Employers that plan to apply to have a security guard training program certified as a Recognized Security Training Program should confirm that they will be able to show that they have at least five years of experience providing training relating to Security Services (defined above), and if so, begin collecting information to support their application; identifying a program director and instructors; planning an in-person or on-line interactive course curriculum to meet the minimum requirements of the law; and allocating personnel and budget for the application process, the cost of developing and presenting the new hire and annual training, complying with recordkeeping and reporting requirements, and paying Security Employees for their time spent in training at their regular hourly rates.  

Finally, even those employers that plan to engage a nonprofit vendor to provide the training or outsource security guard services should still familiarize themselves with the law’s requirements, and plan to pay for the cost of the training and for the time spent in training.