Somewhere in a Beaumont office there is a spreadsheet of officers and expiration dates, and this month a scheduler highlighted your row and sent you a message about it. Useful as that is, the spreadsheet only knows one thing about your renewal. The rule knows several.

What a Date on a Roster Doesn’t Capture

Renewal tracking systems record when a license expires. What they rarely record is that under §35.161(a) of the Texas Administrative Code, the renewal application may not be submitted until the required minimum continuing education hours have been earned, so an officer who is “on track” by the spreadsheet’s reckoning may still be unable to file. The training has to happen first, and it has to be the right training.

The requirement sits in §35.161(g). Commissioned security officers and personal protection officers complete six hours of continuing education, and they do it by completing the renewal portions of the Level III or IV training course, as applicable. The rule further requires that the continuing education be taught by department-approved training schools and instructors, and it requires a commissioned security officer to submit a firearms proficiency certificate with the renewal application.

An Approved School, and Nowhere Else

Contractors staffing industrial accounts along the Gulf Coast often maintain substantial internal training operations, and it is a natural assumption that an employer of that size can supply its own officers’ continuing education. For armed officers the rules say otherwise, twice over. §35.162(d) provides that the in-house continuing education exemption for companies with ten or more licensed employees does not apply to commissioned security officers or personal protection officers. §35.162(f) provides that credits earned through outside entities may not be used to satisfy their requirement. What remains is the renewal portion of the appropriate course, delivered by an approved school. The provisions are in 37 TAC Chapter 35 if a supervisor wants to see them in writing.

“Within Two Years” Is a Test the Hours Have to Pass

People summarize this as renewing every two years, which is close enough for conversation and wrong in practice. §35.161(n) says continuing education is valid only if completed within the two-year period preceding the license’s current expiration date. It is a test applied to the hours themselves. Training completed outside that window does not satisfy the requirement, and no amount of good faith on the officer’s part or good record-keeping on the employer’s changes that.

Part of the Roster Owes Nothing Here

Officers working unarmed under a Level 2 non-commissioned license have no continuing education obligation at all, because §35.161(b) specifically exempts noncommissioned security officers. On a mixed roster that distinction saves real time, since chasing certificates from officers who do not owe them is a common way for a compliance review to stall.

Among the officers who do owe hours, keep the credentials distinct. Level 3 is the commissioned security officer. Level 4 is the personal protection officer. The close protection credential, not a promotion above Level 3. They are separate licenses that share a renewal pathway because §35.161(g) addresses both and directs each to the renewal portion of its own course.

Plant Gates, Port Terminals and the Shift Problem

Beaumont and the wider Golden Triangle carry an unusually heavy concentration of armed posts for a market this size, because refining, petrochemical and marine terminal operations run continuously and their access control does not pause for anyone’s training calendar. Add turnaround seasons, when contractor traffic through a gate multiplies for weeks at a stretch, and pulling an officer off a post for a full day of classroom time becomes something a site manager actively resists.

That is why the classroom half of our renewal runs 100% online: six hours you can work through between rotations rather than surrendering a scheduled day. The scope is worth stating plainly: the online enrollment covers the online training only, and the in-person firearms qualification is not included, being scheduled separately after the online portion is complete. Our full class listing shows where renewal sits relative to everything else we run.

The Records Live in Three Places

Your employer maintains proof of completion in your personnel file and you indicate completion on the renewal application, both under §35.161(a). The school issues a certificate of attendance under §35.162(b)(3) carrying your name and license number, the date of attendance, the number of hours and the courses attended, signed and dated by the school director, and retains its own records for two years. And §35.161(m) puts a duty on you directly: keep your certificates of completion for two years and furnish copies to the department on request. Ours for this course is the certificate identified as PSP 31. Three sets of records, and only one of them is yours to control, which is the practical argument for keeping your own copy somewhere you can reach it the day a client audit lands.

The Rows That Don’t Fit the Spreadsheet

Military service members are given two additional years under §35.182 to complete a continuing education requirement or any other renewal-related requirement, and §35.181 waives late-renewal penalty fees for them. A provision that rarely surfaces in a tracking system and has rescued more than one license. At the other end, §35.141(d) requires an inactive or expired licensee who has not been employed in the industry for three years or more to submit current training certificates to the department, which may point toward the full Level 3 course rather than renewal training. Licensing itself runs through the Texas DPS Private Security Bureau.