FAQs about Dallas's Law
Q: Who is required to complete the additional de-escalation, safe restraint, CPR, and first aid trainings under Tennessee Chapter 1121 of Public Acts of 2022, also known as “Dallas’s Law”?
A: Any unarmed or armed security guard who is providing security or patrol services at an establishment that is licensed/permitted to serve alcoholic beverages for on-premises consumption must complete these trainings. Security guards who are required to complete these additional trainings will also need to complete refresher trainings on these subjects prior to renewing their registration cards.
Q: When do these additional trainings need to be completed by?
A: Effective January 1, 2023, these new trainings must be completed within fifteen (15) days of employment by the security guard who is providing services at an establishment for on-premises consumption. Security guards who are already employed by a Proprietary Security Organization (PSO) or a contract security company providing security at an establishment serving alcohol for on-premises consumption should complete these trainings by January 16, 2023.
Q: Where can these trainings be completed?
A: These trainings can be completed by a trainer who is certified by the Tennessee Detection Services Licensing Program to provide these trainings or a qualified training provider. If you complete these trainings from an individual/company who is not certified by the Program, you will need to submit a certificate and/or any other proof to the Program that you have completed training that is acceptable in order to meet requirements under Dallas’s Law. If you have any questions about whether a certified trainer is certified to provide certain trainings, you may check the trainer’s status on https://search.cloud.commerce.tn.gov/ and/or by contacting the Program.
Q: If I am a certified trainer who wants to provide these new trainings to security guards, how do I become certified by the Program to provide these trainings?
A: Certified trainers who wish to be certified by the Program to provide the trainings under Dallas’s Law to security guards may contact the Program to submit an application and proof of being qualified to provide these additional trainings. Proof of qualifications to provide these trainings may include a certificate from a nationally recognized organization, law enforcement agency, or other organization certifying individuals to provide these trainings to security guards. A certified trainer may be certified in any or all of the new trainings required by Dallas’s Law.
Q: Are there any new training requirements under Dallas’s Law as part of renewing registration as an unarmed security guard?
A: All unarmed security guards renewing a registration for an unarmed card after January 1, 2023, will need to complete two (2) hours of refresher training related to the general guard training prior to renewing their registration.
Q: How does Dallas’s Law affect “PSO’s?
A: PSO’s that hold a license or permit from the Alcoholic Beverage Commission and/or a local beer board to serve alcohol for on-premises consumption will need to complete a new application for a specific PSO registration the Program refers to as a PSO-A registration. This registration is only required for PSO’s that hold the above-referenced permit/license and will require:
- Payment of a $100 registration fee;
- Proof of appropriate insurance coverage;
- Current copy of the ABC license and/or beer permit;
- Proof of electronic fingerprint submitted by a qualifying manager
NOTE: This PSO-A registration will expire after 2 years and will need to be renewed with a $100 fee.
Q: Who is authorized to discipline an Alcoholic Beverage Commission license or beer board permit under Dallas’s Law?
A: Although the Alcoholic Beverage Commission (“ABC”) and beer boards are named under Dallas’s Law and the Detection Services Licensing Program’s statutes to discipline their license/permit holders if they employ improperly registered guards, only the ABC Commission or beer board will have authority to suspend or revoke a liquor license/beer permit. The Detection Services Licensing Program will still have authority to discipline security guards, companies, and trainers. If you have questions regarding if your ABC or beer board license/permit is subject to discipline by either of these entities, you should contact them for further information.
Q: As of January 1, 2023, what will be required to renew an unarmed guard renewal application?
A: All unarmed guards will be required to complete two (2) hours of refresher training by a state certified trainer and complete a renewal application that includes a head-and-shoulder color photo.
Any unarmed or armed security guard who is either employed by a PSO that is licensed/ permitted to serve alcoholic beverages for on-premises consumption or employed by a contract security company to provide security services at a commercial establishment that holds a license/permit to serve alcohol for on-premises consumption will also need to complete refresher trainings for de-escalation, safe restraint, CPR, and first aid prior to renewing their registration cards.
Q: Can I continue to carry my less than lethal weapon as an unarmed guard after January 1, 2023?
A: If you are an unarmed guard working for any PSO, then you cannot carry any type of weapon including less than lethal devices. This prohibition applies to all unarmed guards working for PSO’s, regardless of whether the PSO holds an ABC license or beer board permit. If you are an unarmed guard working for a contract security company, then you may continue to carry the less than lethal device(s) if you are properly certified.
Q: Are there any exemptions to Dallas’s Law?
A: There are no exemptions for Dallas’s Law outside of the registration exemptions for individuals listed under T.C.A. 62-35-103.
Q: How do these new requirements impact fees?
A: At this time, there are no new fees associated with Dallas’s Law requirements unless a guard or trainer is requesting a new/duplicate registration card or certificate to reflect any new certifications.
Q: Who should I contact if I’m not sure that my training is compliant or I need assistance applying?
A: You may contact the Detection Services Licensing Program by e-mail at private.protective@tn.gov or by phone at 615-741-6382.
Q: Does everyone employed by a PSO that holds an ABC license have to comply with these requirements?
A: Only individuals who provide security or patrol services will need to comply with the new training requirements under Dallas’s Law. Waiters, bartenders, or other employees working for the PSO who are not providing security services will not need to complete the additional training requirements unless they also provide security services for the establishment.
Q: Can security guard training be completed online or virtually?
A: The Program has approved of the following trainings for security guards to be completed online:
- The general four (4) hour unarmed guard training;
- The two (2) hour unarmed guard refresher training;
- The additional trainings required by Dallas’s Law, including the first aid, CPR, de-escalation, and safe restraint training; and
- The refresher trainings required by Dallas’s Law, including the first aid, CPR, de-escalation, and safe restraint training.
Q: What security guard training is not approved to be completed online or virtually?
A: The Program has NOT approved of any of the armed guard trainings to be completed online or virtually.
Tenn. Code Ann. § 62-35-118(b) lists the training requirements for armed security guards. Specifically, armed security guards must complete at least eight (8) additional classroom hours of firearms training administered by a certified trainer and pass an examination covering at least the following subjects: legal limitations of the use of a firearm; handling of a firearm; and safety and maintenance of a firearm. Based on this statute requiring this training to be completed in a classroom and the subject matter being related to appropriately handling firearms, the Program requires this training to be completed in-person and through live, classroom instruction to ensure all armed security guards are appropriately instructed in the proper use of firearms.
The classes include eight (8) hour classroom training, the four (4) hour marksmanship training, and the refresher trainings for armed guards
Additionally, armed security guards must complete at least four (4) hours of marksmanship training administered by a certified trainer and achieve a minimum of seventy percent (70%) on an approved silhouette target course. No virtual or online target courses have been approved to meet this requirement.
Although security guards may complete additional online classes above these statutory minimum requirements, the trainings listed above that are not approved for online or virtual formats must be completed live and in-person with a certified trainer in order for the security guard to be approved for a registration card. The completion of a non-approved training may result in the denial of a security guard’s application for a registration card.
NOTE: Nothing in the FAQs shall be construed to limit a certified trainer’s ability to use videos or electronic aids within a classroom training nor shall a certified trainer be limited in the trainer’s ability to use a computer-based or typed examination following an in-person, live classroom training.