5.1 Installation and Service Labels (§§ 34.620–34.621)

Why This Section Matters

Texas fire alarm work is documented with labels, not with the punched cardstock tags used for portable fire extinguishers under other subchapters of 28 TAC Chapter 34. The five fire alarm labels — installation, service, inspection/test, yellow, and red — each have their own rule, color, placement, retention and notification requirements. Confusing them is the fastest way to lose points on TFM11.

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1. The Five-Label System at a Glance

All five are approximately three inches high by three inches wide with adhesive on the back, and all five carry "DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL" in all capital letters in at least 10-point bold face type.

Two frequent errors. (1) The service label is white, not blue — blue belongs to the inspection/test label. (2) The installation label goes inside the cover; the yellow and red labels go outside, where an inspector or occupant can see them.

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2. The Installation Label (§ 34.620)

When and where

"After the completion of an installation of new fire alarm equipment or a new system, or the extension, alteration, or modification to a fire alarm system already in place, an installation label must be affixed to the inside of the control panel cover or, if the system has no panel, in a permanent location."

The rule adds an explicit prohibition: "Yellow or red labels must not be attached for the installation of a new system or new equipment used in the extension, alteration, or modification to an existing fire alarm system." A brand-new system is not "non-compliant" or "impaired" merely because it has not yet been accepted.

Physical specification

Required content (§ 34.620(d))

1. "DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL" — all capitals, at least 10-point bold face
2. "INSTALLATION RECORD" — all capitals, at least 10-point bold face
3. The registered firm's name, address, and telephone number and the certificate of registration number (main office or branch office) of the firm performing the installation
4. The installation date, the licensee's signature — a stamped signature is prohibited — and the license number
5. The name and license number of the fire alarm planning superintendent or residential fire alarm planning superintendent (as applicable), or the professional engineer's name and license number, who planned the system

Item 5 is the giveaway on a Texas installation label: it names two people — the installer/certifier and the planner. That is the label-level expression of § 34.619(a).

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3. The Service Label (§ 34.621)

When and where

"After any service, a fire alarm service label must be completed in detail and affixed to the inside or outside of the control panel cover or, if the system has no panel, in a permanent location. The signature of the licensee on the service label certifies that the service performed complies with requirements of law."

The label-clearing function (§ 34.621(b))

"If the service performed corrects all conditions noted on a yellow label or red label, the color and date of the label shall be marked on the service label and the respective yellow or red label removed."

So the service label is the instrument that clears a yellow or red condition. You do not simply peel off the yellow label — you record its color and date on the service label first.

The label-triggering function (§ 34.621(c))

"If during any service it is observed that the system does not comply with applicable standards adopted at the time the system was installed, has a fault condition, or is impaired from normal operation, the owner or the owner's representative and the local authority having jurisdiction must be notified of the condition and the licensee must attach, in addition to the service label, the appropriate yellow or red label."

Note the benchmark: compliance is measured against the standards adopted at the time the system was installed — consistent with the § 6002.002 definition of maintenance as performance "as originally designed or intended."

Physical specification and retention

Required content (§ 34.621(h))

1. DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL (all caps, ≥10-point bold)
2. SERVICE RECORD (all caps, ≥10-point bold)
3. The registered firm's name, address, telephone number (main or branch) and certificate of registration number
4. The date of service performed, the licensee's signature (stamped signature prohibited), and license number
5. A list of services performed
6. The type of service performed — either general service or the correction of conditions that resulted in a red label or yellow label

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4. Who May Attach a Label

Section 34.616(b)(2) supplies the missing piece: "The licensee attaching a label must be licensed under the ACR number of the primary registered firm." And § 34.606(19) defines the primary registered firm as the registered fire alarm company responsible for the fire alarm system certification.

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5. Worked Fact Patterns

Pattern A. A crew finishes a new system and the technician places a white installation label on the outside of the panel door. → Wrong location. Section 34.620(a) requires the installation label inside the control panel cover (or in a permanent location if there is no panel).

Pattern B. A technician performs routine service, finds everything compliant, and signs a service label. → Correct. The signature certifies that the service complies with requirements of law. Stack it over the previous service label using about ½ inch of adhesive at the top.

Pattern C. During service the technician finds a failed notification appliance circuit. → Section 34.621(c) applies: notify the owner or representative and the local AHJ, and attach the appropriate yellow or red label in addition to the service label.

Pattern D. A repair corrects everything listed on a yellow label attached three weeks ago. → Section 34.621(b): mark the color and date of the yellow label on the service label, then remove the yellow label — and under § 34.623(d) notify the local AHJ of the removal within five business days.

Pattern E. A property manager peels off two-year-old service labels to tidy the panel. → Improper. Only a licensed employee or agent of a registered firm, an SFMO employee, or an authorized governmental representative may remove labels.