3.1 The Six Texas Fire Alarm Licenses and What Each May Do

Why This Section Matters

Scope-of-practice questions are the backbone of TFM11. The rule text is unusually literal: each license is defined by a list of verbs. Learn the verb lists and the "may act as" chain and you can answer any scope question by elimination.

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1. The Eight Licenses and Approvals (§ 34.611(a))

The acronyms matter. TDI uses AMT for the monitoring technician (not "FAL-M"), RAS-SS for the single-station superintendent, and APS for the planning superintendent. Answer options built on invented acronyms are distractors.

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2. The "May Act As" Chain (§ 6002.154(d))

"A fire alarm technician may perform or supervise monitoring. A fire alarm planning superintendent may act as a fire alarm technician or a residential fire alarm superintendent. A residential fire alarm superintendent may act as a fire alarm technician."

Draw it as a one-way ladder:

        APS  (may act as FAL and as RAS)
         |
         v
        RAS  (may act as FAL)
         |
         v
        FAL  (may perform or supervise monitoring)

The ladder never runs upward. An FAL does not become an RAS by working residential jobs, and an RAS does not gain commercial planning authority.

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3. Planning Is the Dividing Line (§ 34.619(a))

"Each fire alarm system or modification to an existing system must be planned by a person holding a fire alarm planning superintendent license or a residential fire alarm superintendent license, as applicable, or a Texas registered professional engineer."

So the full set of people who may plan a system in Texas is: APS, RAS (residential scope), RAS-SS (single-station scope, per § 34.611(a)(4)), and a Texas registered PE. The FAL, AMT and RAL licenses carry no planning authority at all.

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4. The Residential Licenses Compared

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5. Employment and Proof (§ 34.611(b), (f))

• § 34.611(f)(1): A licensee must not engage in any act of the business unless employed by or as an agent of a registered firm and holding an unexpired license. Both conditions, at all times.
• § 34.611(f)(2): Each person who engages in the activities of the business must hold the appropriate license unless excepted by § 6002.155.
• § 34.611(b)(1): A licensee must be able to show proof of licensure while engaged in the activities of the business.
• § 6002.154(c): To engage in the activity for which the license is granted, a licensee must be an employee or agent of an individual or entity holding a registration certificate.
• § 6002.204 / § 34.613(d)(2): A licensee with an unexpired license who is not employed by a registered firm at renewal time may renew, but may not engage in any activity for which the license was granted until employed and qualified by a registered firm.

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6. Worked Scope Problems

Problem 1. An FAL is handed a set of drawings by a general contractor and asked to "figure out where the strobes go" in a new tenant suite. → Not permitted. Device layout is planning. Under § 34.619(a) the layout must come from an APS, an RAS (residential), or a Texas PE, and § 34.619(b) requires the planner's signature and license number on the plans.

Problem 2. An APS wants to perform the final acceptance test and sign the installation certificate personally. → Permitted. § 6002.154(d) lets an APS act as an FAL, and § 34.616(b)(1) requires the certifying licensee to be present for the final acceptance test.

Problem 3. An AMT is asked to replace a failed dialer card at a subscriber's premises. → Not permitted. § 34.611(a)(2) limits the AMT to monitoring. Replacing equipment at the protected premises is servicing, which requires an FAL, RAL, RAS, or APS under § 34.616(b)(2).

Problem 4. An RAL is left alone on a two-family dwelling job with an unlicensed helper. → Permitted, narrowly. § 6002.154(d-1) allows an RAL to provide direct on-site supervision to an employee of a registered firm for work in a single-family or two-family dwelling. The same RAL could not supervise that helper on a strip-center job.

Problem 5. A newly licensed FAL leaves her employer and takes a side job installing a small system for a friend's business, invoicing personally. → Prohibited. § 34.611(f)(1) and § 6002.154(c) require employment by or agency for a registered firm; the friend's business would also need a registered firm on the job. This is a § 6002.301(1) prohibited practice and a Class B misdemeanor under § 6002.351.