4.1 Sales, Installation and Service Rules (§ 34.616)

Why This Section Matters

If TFM11 has a "how do I actually run a job in Texas" section, this is it. Section 34.616(b) answers four questions that come up on every project: who must be there, whose ACR number applies, what counts as a repair, and what the owner is entitled to receive.

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1. Direct On-Site Supervision (§ 34.616(b)(1)–(2))

"The installation of all fire detection and fire alarm devices or systems, including monitoring equipment ... must be performed by or under the direct on-site supervision of a licensed fire alarm technician, residential fire alarm technician, residential fire alarm superintendent, or a fire alarm planning superintendent for the work permitted by the license."

The identical requirement applies to maintenance or servicing in § 34.616(b)(2).

"Direct supervision" is a defined term. 28 TAC § 34.606(8): "The control of work, excluding the installation of conduit, raceways, junction boxes, back boxes, or similar electrical enclosures, as it is being performed on fire detection or fire alarm devices and systems by a licensed fire alarm technician or a licensed fire alarm planning superintendent."

Two consequences fall out of that definition:

1. Rough-in raceway work is carved out. Installing conduit, raceways, junction boxes, back boxes, and similar enclosures is expressly excluded from the definition of direct supervision — which is how electrical contractors lawfully rough in a job before the alarm contractor arrives.
2. "Direct" means "on-site" and contemporaneous — "as it is being performed." Phone supervision from another job is not supervision.

The phrase "for the work permitted by the license" limits each supervisor to their own scope: an RAL may supervise only work in a single-family or two-family dwelling (§ 6002.154(d-1)).

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2. Which ACR Number Applies

Section 34.616(b)(1) closes with the sentence that makes split projects legal: "The registered firm responsible for the planning of the fire devices or system can be different from the firm responsible for the installation."

28 TAC § 34.606(19) defines primary registered firm as "the registered fire alarm company with the responsibility for the fire alarm system certification." So when a design-build firm plans a system and a second firm installs it, the installing firm certifies and its licensee attaches the labels.

The certifier must be physically present. "The certifying licensee ... must be present for the final acceptance test prior to certification." Certifying a system from paperwork you did not witness is a direct rule violation and a § 6002.301(3) prohibited practice.

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3. Crossing Trades (§ 34.616(b)(3))

"If the installation or servicing of a fire alarm system also includes installation or servicing of any part of a fire protection sprinkler system or a fire extinguisher system, the licensing requirements of Insurance Code Chapters 6001 and 6003 must be satisfied, as appropriate."

• Chapter 6001 — Fire Protection Sprinkler System Service and Installation
• Chapter 6003 — Fire Extinguisher Service and Installation

Wiring a tamper switch to the panel is fire alarm work. Installing the tamper switch on the valve, or servicing the kitchen hood suppression system it monitors, reaches into Chapter 6001/6003 territory and requires those separate credentials.

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4. Which Edition Applies (§ 34.616(b)(4))

Planning, installation, and servicing must follow the standards adopted in § 34.607 — except when the planning and installation complies with an edition of the standard previously adopted by the political subdivision where the system is installed. That is the field-level counterpart to § 6002.003(b)(2), which lets local government require a better system than the state minimum.

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5. Repair vs. Modification (§ 34.616(b)(5))

This is the most practically valuable rule in Subchapter F:

"Fire alarm system equipment replaced in the same location with the same or similar electrical and functional characteristics and listed to be compatible with the existing equipment, as determined by a fire alarm planning superintendent, may be considered a repair. The equipment replaced must comply with the currently adopted standards, but the entire system is not automatically required to be modified to meet the applicable adopted code. The local authority having jurisdiction must be consulted to determine whether to update the entire system to comply with the current code and if plans or a permit is required prior to making the repair."

Five conditions must all hold: same location, same or similar electrical and functional characteristics, listed compatible, determined by an APS, and the new component itself meets current standards. Then the AHJ consultation is mandatory, not optional.

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6. The Password Rule (§ 34.616(b)(6))

"On request of the owner of the fire alarm system, a registered firm must provide all passwords, including those for the site-specific software, but the registered firm may refrain from providing that information until the system owner signs a liability waiver provided by the registered firm."

Texas resolved the industry's "we own the programming" dispute in the owner's favor, with one procedural condition. The firm cannot refuse outright; it can only condition delivery on a signed waiver.

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7. Recordkeeping (§ 34.616(d))

"The firm must keep complete records of all service, maintenance, and testing on the system for a minimum of two years. The records must be available for examination by the state fire marshal or the state fire marshal's representative."

Two years is the retention period for service, maintenance, and testing records — not for everything. Installation certificates, installation inspection forms, and residential drawings have their own, longer periods (see § 5.3 of this guide).