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.

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BIO LINKS

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(615) 669-3121

 

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6 Key Responsibilities of a Security Guard

 

Six Key Responsibilities of a Security Guard

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If you are considering becoming a security guard, you may think the job is relatively straightforward: provide security. While this is your primary function, there is much more to your general duties than that simple summary suggests.

Here, we look at six key responsibilities that may be placed on your shoulders as a security guard.

1. A Sense of Security

To the person employing you, you provide genuine security services – preventing theft in retail settings, intruders in offices, and fights/drunken behavior in bars, for example. To the on-site staff and the public, you provide something subtly different: a sense of security.

This is a crucial distinction. Wherever you are stationed, you will make the people around you feel safer by being there. Your presence is invaluable whether they acknowledge this consciously or it is a subconscious response. These people know that there is someone they can turn to if there is an emergency and that if a situation arises, that could turn dangerous, they know you will take care of it.

2. Controlling the Flow of Traffic

Controlling traffic applies to both vehicular and foot traffic. As the person responsible for maintaining a sense of order and control, you may be called upon to direct, manage, or restrict traffic. 

Before your shift, you should find out from the site management what the expectations are. Clear expectations are essential if you work at an event or festival site where poor traffic and crowd flow can mean the difference between a successful event and a failure.

3. Crowd Management

Regarding providing security at events, you may have to provide crowd management services. Concerts and sports games (this latter, in particular) can be powder kegs of emotional individuals waiting to explode in the form of crowd surges and fights. 

You must rely heavily on your risk assessment and situational awareness training here. You do not want to step in when people are just having a good time (that is what they are supposed to be doing, after all), but when the mood turns boisterous to belligerent, it is time to make your presence felt.

When dealing with crowds, you will undoubtedly want to include your fellow security guards or local law enforcement officers if they are on site. Otherwise, you could quickly find yourself overwhelmed and being the instigator of the unrest you were hoping to avoid.

4. Guidance, Directions, and Advice

Whether stationed at the door of a business or event or on patrol, you will probably find yourself asked for directions at some point. This could be something as simple as where to find the person or department that the individual is there to see, or it could be something more in-depth like where is the best place to park.

Either way, it is in your best interest (and that of your employer) that you know the site well. A surly, unresponsive, or unhelpful attitude will not build up your reputation as a competent and professional security guard – and if you have a complaint raised against you for any reason, you could find yourself replaced very quickly.

There are also professional benefits to you; the last thing you want is random public members roaming your site aimlessly. Giving them clear and accurate directions will minimize their time on your radar.

5. Call the Emergency Services

If an emergency arises, it will likely fall to you to ensure that the emergency services are informed promptly. This covers the full range of 911 responders (fire, EMT, and police) – whoever is the most appropriate service provider for the incident underway.

You will need to handle this while simultaneously managing the emergency itself. Suppose you are the only person in the vicinity with any first aid experience or training when someone collapses. In that case, you must either demand that a bystander make the call or do it yourself in conjunction with administering first aid.

Ensure that your phone and radio communications always have more than enough charge for your shift and are easily accessible for emergency usage.

6. Security Reporting

After any incident, and particularly those that require emergency services to be present, you will need to write a detailed and accurate report for your employer – and potentially for law enforcement and insurance companies, depending on the nature of the event.

As such, your observational and communication skills must be highly developed. The slightest mistake here could cause issues for everyone involved further down the line, so you must ensure you are 100% comfortable filling out a report for various stakeholders.

Human memory can play tricks on you. Every detail can be subconsciously affected by what others say and do. For the best results, you should write down the essential details as soon as possible, ideally in a quiet, isolated place.

It is your ethical responsibility to be truthful in your report. If you made a mistake, or the situation was partly due to your employer or client, it still needs to be accurately reported. Stick with the facts.

Alliance Training and Testing

If you want to develop the skills you need when working as a security guard, contact the Alliance Training and Testing team. We provide a range of security training courses, all widely acknowledged as among the most comprehensive in Tennessee. Our team can help you obtain or renew your security license and become a better, more well-rounded security professional.

https://sleek.bio/guardtrainingtn

@GuardTrainingTN

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