The security licensing process and requirements can be somewhat perplexed. If you are a security professional and would like to know if you have to renew the level-2 license if you currently hold a level-3 license, then reading this will certainly eliminate some of your confusion.
There are some unspecified and unstated guidelines regarding the Level-2 (Non-commission license) and the Level-3 (Commission license).
Many in the industry have expressed and passed on to others (from a non-official standpoint), that “once you get your Level-3 Commission license, you no longer need your Level-2 Non-commission license and you no longer need to renew it.” Some also state that “a Level-3 (Commission license) ‘outranks’ a Level-2 (Non-commission).”
In theory, these points or arguments made by many sound reasonable and make sense. The problem is that there is NO regulation, rule, code, or law to back this claim up at all – anywhere.
We too, agree that an officer who has gone through a 40 hour Commission class surely “outranks” a Level-2 officer as far as licensing, and as such, should be able to perform both (armed & unarmed) using only the Commission license depending on what account the security company assigns the guard to.
Again, nothing in any code or rule allows for this, so we contacted DPS and emailed the Licensing Supervisor, and after outlining the issue at hand, this was his response:
“Depending what assignment you will be working will be decided by the security company; however, you must be specifically licensed for that regulated duty you are performing.”– DPS Licensing Supervisor
Anyone that has ever dealt with DPS-Private Security Bureau /Board /Commission /Project (the name keeps changing), will agree that many times you will not get a simple “yes” or “no” for whatever reason.
With the lack of clear defined regulations regarding this, we have to go on what their understanding is on the matter at hand and how DPS wants this dealt with so that we won’t be in jeopardy of being in violation and/or fined.
Reading the Licensing Supervisor’s email response, we can only understand this as if you are working in an unarmed capacity, then you should have a “Non-commissioned” license; if you are working in an armed capacity, then you should have a “Commissioned” license. There is no such thing as one license “outranking” another – to be clear here.
This is another one of those things in a long list of many areas that needs to be addressed and corrected as the industry continues to grow and question/study the regulations a lot more closely than past years.
Remember, it is not the fact you take your firearm off that makes you a Non-commission officer, it is that pocket card you carry that says so. With a Level-2 Non-commission license only being $35.00 which is good for two full years, we would just recommend keeping both your Level-2 and your Level-3 current at all times so that you can work both armed or unarmed as needed and you won’t be at risk of a ticket.
Some Officers say they will never work unarmed again, but if your company has a client that only wants unarmed guards, then you don’t have a choice if you want to work, so you might want to keep both current.
For more information about security licensing, contact TCTA.