Tennessee Private Protective Services - Review of Upcoming Changes

  

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This post summarizes the key changes and ongoing developments related to Tennessee's Private Protective Services regulations. The provided documents outline amendments to Tennessee's regulations governing private protective services, driven mainly by the implementation of "Dallas' Law." These revisions clarify training requirements for security personnel in establishments serving alcohol and armed guards in schools, detailing acceptable proof of completion. The updates also modify application procedures for security guard registration, including handling incomplete submissions and status changes between armed and unarmed. Furthermore, the rules adjust various licensing and renewal fees for security guards and certified trainers to maintain the financial self-sufficiency of the regulatory program.

EXECUTIVE SUMMARY

Through its Detection Services Licensing Program, the Tennessee Department of Commerce and Insurance has recently filed amendments to its rules governing Private Protective Services (Chapter 0780-05-02). These amendments, primarily based on a previous emergency rule and stemming from "Dallas' Law," mainly focus on training requirements and licensure fees for unarmed and armed security guards and certified trainers. The changes also address definitions, the status of sworn peace officers, application processes, authorized weapons, and investigative procedures.

Concurrently, the Tennessee General Assembly is considering two bills (HB 89 and SB 349) that propose amendments to the Private Protective Services Licensing and Regulatory Act. These bills could potentially impact the exemptions and regulations concerning peace officers and reserve/auxiliary law enforcement providing security services.

IMPORTANT FACTS

Implementation of "Dallas' Law" Training Requirements:

The rulemaking hearing rules reflect the implementation of training requirements likely related to "Dallas' Law," focusing on active shooter training for school security personnel.

Rule 0780-05-02-.10(g) is amended to include "De-escalation techniques" and "Proper and safe restraint techniques" as additional classifications of training that a certified trainer can administer.     

Rule 0780-05-02-.10(6) now specifies that training related to active shooter situations can be provided by a certified trainer, a recognized/accredited program approved by the Commissioner, an individual training program deemed sufficient by the Commissioner, or applicable law enforcement training approved by the Commissioner.

Tennessee Code § 62-35-118(e) mandates active-shooter training (at least 8 hours) for armed security guards or officers providing services in public, charter, private, or church-related schools.

Redefinition of "Employed": The definition of "Employed" is amended to mean "to receive compensation, in any form, for the performance of security guard services and/or patrol services."

Application Denial and Reapplication: Rule 0780-05-02-.08(f) clarifies that if a security guard registration is denied based on a criminal record, the individual must cease all security guard activities immediately and cannot reapply for six months.

Pending Applications in Schools: Security guards/officers working on pending applications in schools must always carry proof of all necessary training requirements on their person (Rule 0780-05-02-.08(g)).

Examination Administration: Examinations for new registration cards will now be administered and graded by the applicant's certified trainer (Rule 0780-05-02-.09(1)). These exams should focus on general security knowledge, not specific company policies, and are subject to Commissioner review.

Change in Guard Status: A significant change is implemented regarding changing guard status (Rule 0780-05-02-.23(4)(d)). Individuals wishing to change from armed to unarmed or vice versa will now be required to complete a new application and pay all applicable initial application and licensing fees rather than a downgrade application. The response to a public comment confirms this: "Yes, Tenn. Comp. R. & Regs. 0780-05-02.23, as proposed, would require a new initial application be completed rather than an application for downgrade.

FEES INCREASE 

Tennessee Private Protective Services Fee Changes Effective June 19, 2025

Rule 0780-05-02-.23 outlines increases in application and renewal fees for security guards and certified trainers. The new security guard fee increases outlined in Rule 0780-05-02-.232 are set to take effect on June 19, 2025. Below is a summary of the updated fees:

Armed Security Guard:

- The application fee has increased from $75 to $100 plus any fingerprint processing fees

- The registration fee remains at $30.

Total (Old) $105, plus any fingerprint processing fees

Total (New) $130, plus any fingerprint processing fees

 Armed Renewal:

- The timely renewal fee has been raised from $60 to $85

- The late renewal penalty remains $20 monthly for up to three months.

Unarmed Security Guard:

- The application fee has increased from $50 to $75, plus any fingerprint processing fees

- The registration fee remains at $20

Total (Old) $70, plus any fingerprint processing fees

Total (New) $95, plus any fingerprint processing fees

Unarmed Renewal:

- The timely renewal fee has increased from $50 to $70

- The late renewal penalty remains $20 monthly for up to three months.

Other Fees:

- The fee for a duplicate certification, license, or registration is $25

New Fees:

- The application fee for adding classifications (e.g., Dallas Law and Active Shooter) to a security guard registration card is a nonrefundable $25\

CHANGES IN THE LICENSURE & APPLICATION PROCESS

Additionally, the rule clarifies that individuals changing their registration status from unarmed to armed or vice versa must complete a new application and pay all applicable fees. 

The rationale for these increases is to "maintain the statutorily required financial self-sufficiency of the Program."

Regulations Regarding Sworn Peace Officers:

Rule 0780-05-02-.03 is amended to clarify that while the Act doesn't apply to full-time sworn peace officers receiving compensation as security guards under contract with licensed private businesses or registered proprietary organizations, this exemption does not relieve the companies or organizations themselves from the Act's requirements (e.g., registration or licensing).

Authorized Weapons:

The definition of a "Stun gun" has been updated to specify that it is "designed and manufactured for self-defense which emits an electrical spark which may momentarily disable a person."

Rule 0780-05-02-.15(1)(c) is strengthened to explicitly state that no security guard/officer shall carry a firearm while acting in that role unless adequately registered and certified, regardless of whether they possess a handgun carry permit as a private citizen. The previous rule had a similar intent, but the new language is more direct.

The list of approved firearm calibers remains largely the same, including standard .38 special, 9mm, .45 ACP, and 12-gauge shotgun, with the addition of ".357 SIG" and ".40 S&W" to the specific examples.

Changes of Address and Employer:

Rule 0780-05-02-.16(2) is amended to require registrants to notify the Commissioner in writing within ten (10) days of any change in residential address. The requirement to notify of a change in employer has been removed in this amendment.

Investigations and Complaints:

Rule 0780-05-02-.18(3) is added, requiring any licensee, registrant, or entity subject to T.C.A. § 62-35-142 to maintain a guard roster and provide it upon request by the Commissioner. Failure to do so violates T.C.A. § 62-35-130(a)(11). This adds clarity to what constitutes non-cooperation during an inquiry. 

GUARD ROSTER REQUIREMENT

"Any licensee, registrant, or other Individual. Partnership. company, corporation, or entity required to comply with T.C.A. § 62-35•142 shall maintain a copy of its guard roster and provide such guard roster upon request of the Commissioner or l1is/her designees. Failure to immediately furnish a copy of the requested roster is a violation of T.C.A. § 62-35-130(a)(11) and any other related provisions under the Act." (03-12-25.pdf, Rule 0780-05-02-.18(3))

POTENTIAL IMPACTS

Security Companies and Guards: Increased costs associated with application and renewal fees. More stringent requirements for changing guard status. Increased emphasis on training, particularly active shooter training for those working in school environments. More explicit expectations regarding cooperation with investigations and the provision of guard rosters.

         

Sworn Peace Officers and Reserve/Auxiliary Law Enforcement: Potential changes to regulations regarding providing security outside their primary jurisdiction if HB 89 passes. Significantly broaden exemptions from private protective services licensing if SB 349 is enacted.

Certified Trainers: Increased renewal fees but more explicit guidelines on the types of training they can administer.

Public Safety: Enhanced training requirements, especially in active shooter situations, could lead to a more prepared security workforce in specific environments.

ADDITIONAL CONSIDERATIONS

The specific content of "Dallas' Law" and its direct mandates on these rule changes would provide further context.

Tracking the progress of HB 89 and SB 349 through the Tennessee General Assembly is crucial to understanding potential future legislative impacts on the private protective services industry.

Reviewing Attachment A, which is mentioned in "03-12-25.pdf," regarding public comments and responses, would offer insights into stakeholder concerns and the agency's rationale for the final rule amendments.

QUOTES FROM ORIGINAL SOURCES

Definition of Stun Gun: "'Stun gun' means a hand-held, electronic control device designed and manufactured for self-defense which emits an electrical spark which may momentarily disable a person." (03-12-25.pdf, Rule 0780-05-02-.02(2)(e))

Requirement for New Application for Change in Guard Status: "Individuals who wish to change registration status from an unarmed guard to an armed guard or from an armed guard to an unarmed guard are required to complete a new application and pay all applicable application and licensing fees." (03-12-25.pdf, Rule 0780-05-02-.23(4)(d))

Rationale for Fee Increases: "Change the application and renewal fees associated with Unarmed Security Guard registration, Armed Security Guard registration, and Certified Trainers to maintain the statutorily required financial self-sufficiency of the Program." (03-12-25.pdf, Regulatory Flexibility Addendum)

Carrying Firearms: "No security guard/officer shall carry a firearm on their person while acting in the role of a security guard/officer regardless of whether or not such individual possesses a handgun carry permit issued by the Department of Safety or is otherwise able to lawfully carry a firearm as a private citizen unless the security guard is properly registered and certified to carry the firearm according to the Act." (03-12-25.pdf, Rule 0780-05-02-.15(1)(c))

GLOSSARY OF KEY TERMS

Act: Refers to the Private Protective Services Licensing and Regulatory Act (Tennessee Code Annotated, Title 62, Chapter 35).

Commissioner: Refers to the Tennessee Department of Commerce and Insurance Commissioner.

Contract Security Company: A private business licensed to provide security guard and patrol services to other entities.

Proprietary Security Organization: An entity that employs security guards solely for its own purposes and is registered with the Commissioner.

Rulemaking Hearing: A formal process by which state agencies in Tennessee adopt new rules or amend existing ones, involving public notice and opportunity for comment.

Registration Card: A credential issued by the Commissioner allowing an individual to work as a security guard (armed or unarmed).

Certified Trainer: An individual qualified and approved by the Commissioner to provide the training required for security guard registration.

Stun Gun: A hand-held electronic control device designed for self-defense that emits an electrical spark to temporarily disable a person.

Chemical Spray: A chemical composition in a handheld dispenser designed for self-defense.

Dallas' Law: Refers to prior legislative changes (not explicitly defined in the provided excerpts but mentioned as influencing the current amendments) related to private protective services training and requirements, particularly concerning school security.

T.C.A.: Abbreviation for Tennessee Code Annotated, the compilation of Tennessee's state laws.

RESOURCES

"03-12-25.pdf" - Department of State Filing for Rulemaking Hearing Rules, Detection Services Licensing Program, filed 03/21/2025, effective 06/19/2025  https://drive.google.com/file/d/17sEgCu_cgunxh35ezIQ2QBqXFqEl04DQ/view?usp=sharing

"0780-05-02.20241222.pdf" - Tennessee Department of Commerce and Insurance, Division of Regulatory Boards, Chapter 0780-05-02 Private Protective Services (current rules).https://drive.google.com/file/d/1KXkzvo1gy0oWvsxhYzKkdMzF5-TbGywn/view?usp=sharing

ALLIANCE TRAINING AND TESTING 

@GuardTrainingTN

Alliance Training and Testing is Tennessee's leading security training and testing services provider. The company offers various courses, including state-approved unarmed security guard training, armed security guard training, online security guard licensing courses, and Dallas Law certification. Alliance Training and Testing is devoted to providing its clients with top-notch security guard training and certification services.

CONTACT

Angel Rodriguez CPP

Owner, Alliance Training and Testing.

BIO LINKS

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(615) 669-3121

 

The Importance of Security Guard Training

 

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Security guards play a vital role in protecting people and property from harm. They work in various settings, including schools, hospitals, businesses, and government buildings. 

To be effective, security guards need to be well-trained in a variety of areas, including:

Physical security: Includes skills such as patrolling, access control, and crowd control.

Communication skills: Security guards must communicate effectively with the public, law enforcement, and other security personnel.

Legal issues: Security guards must be familiar with the laws governing their work, including those regarding the use of force and the protection of civil rights.

Ethics: Security guards are often in positions of trust, so they must be ethical and professional.

Choosing a school like Alliance Training and Testing to provide specialized physical security licensing and certification training ensures compliance with Tennessee requirements. The length and content of the training will vary depending on the security officer’s specific needs.

There are several benefits to providing security guard training, including:

Improved safety: Well-trained security guards can better protect people and property from harm.

Reduced liability: Employers who provide security guard training can reduce their liability in the event of a security incident.

Increased productivity: Well-trained security guards can help to create a safe and productive work environment.

Enhanced customer service: Security guards who are well-trained in customer service can help to create a positive experience for visitors and customers.

Professional development: Security guard training can help security guards to develop their skills and knowledge and to advance their careers.

Security guard training is a significant investment that can improve safety, reduce liability, and enhance customer service. Employers who provide security guard training can reap the benefits of a well-trained security team. Contact Us Today for Assistance!

About Alliance Training and Testing – The Security School of Choice in Tennessee

At Alliance Training and Testing, seasoned industry professionals deliver top-tier security guard training for the entire State of Tennessee. Opting for Alliance Training and Testing means selecting unparalleled expertise in the field.

Security Guard Training Trends

 

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The security guard training trend reflects the increasing demand for well-trained, professional security personnel. As society becomes complex and security threats evolve, organizations recognize the need for a skilled and vigilant workforce to ensure the safety of their assets and personnel. 

Several key factors drive this trend.

Heightened Security Concerns: 

The rising incidence of crime, terrorism, and cyber-attacks has heightened security concerns across various sectors. Organizations invest in robust security measures to mitigate risks and protect their operations. Comprehensive training for security guards is essential to equip them with the knowledge and skills to respond effectively to security incidents.

Compliance: 

One key driver of the security guard training trend is regulatory compliance. Governments and regulatory bodies are imposing stricter security regulations, making it mandatory for organizations to adhere to specific security standards. This includes training and certification of security guards, ensuring their competency and readiness.

Advancements in Technology: 

Technological advancements in the security industry have introduced sophisticated surveillance systems, access control mechanisms, and other security solutions. Security guards require specialized training to operate and maintain these technologies effectively and efficiently.

Expectations: 

Customer and public expectations play a significant role in shaping the security guard training trend. In today's world, safety and security are paramount. Customers and the public expect organizations to prioritize these aspects. By providing well-trained security guards, organizations not only enhance the customer experience but also instill confidence in stakeholders, thereby meeting these expectations.

These trends manifest in security guard training in several ways.

Increased Demand for Specialized Training Programs: 

Organizations seek specialized training programs specialized training programs tailored to their security needs. These programs cover various aspects, including physical security, access control, surveillance, communication, and legal frameworks.

Integration of Technology: 

Training programs incorporate the latest security technologies, such as CCTV cameras, biometric systems, and intrusion detection systems. Guards are trained to operate and monitor these systems effectively.

Focus on Soft Skills: 

In addition to technical skills, training programs emphasize soft skills, such as customer service, communication, and conflict resolution. Security guards are expected to interact professionally and empathetically with stakeholders.

Continuous Learning: 

Security guard training is viewed as an ongoing process. Organizations implement regular refresher courses and workshops to ensure guards stay up-to-date with evolving security threats and best practices.

The security guard training trends benefit organizations and security guards themselves. Well-trained security guards provide higher protection, reduce security risks, enhance customer satisfaction, and contribute to a safer and more secure environment.

Alliance Training and Testing

The Security School of Choice in Tennessee

@GuardTrainingTN