Two of the six classes reach fire alarm work without a residential limit, and the difference between them is one verb. Under 28 TAC § 34.611, the FIRE ALARM TECHNICIAN license is issued for installing, inspecting, servicing, testing, maintaining, monitoring, and certifying fire alarm or fire detection devices and systems. The FIRE ALARM PLANNING SUPERINTENDENT license is issued for planning, installing, certifying, inspecting, testing, servicing, monitoring, and maintaining fire alarm or fire detection devices. Set the two lists beside each other and only one word separates them. That word is what a registered firm can and cannot take on through each of these licensees.

The statute describes the same two roles from the direction of what the person is designated to do, and the phrasing is worth reading because it is narrower than the rule’s verb list suggests. Insurance Code § 6002.002 defines a fire alarm technician as a licensed individual designated by a registered firm to inspect and certify that each system AS INSTALLED meets the standards provided by law, or to perform or directly supervise the servicing or maintaining of a previously installed device or system and certify that service or maintenance. The fire alarm planning superintendent is defined as a licensed individual designated by a registered firm to plan a system conforming to applicable adopted National Fire Protection Association standards or other adopted standards, and to certify that each system AS PLANNED meets those standards. Two different certifications, of two different things, at two different moments in a job.

The consequence is the one this book has flagged since § 1.3, and it is worth stating in its strongest form here. 28 TAC § 34.619 requires each fire alarm system, or modification to an existing system, to 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. A fire alarm technician appears nowhere in that sentence. So a registered firm staffed entirely with fire alarm technicians can install, inspect, test, service, maintain, monitor and certify commercial systems all day, and cannot lawfully decide what goes into one — including when the change is a single device added to a system the firm installed itself.