Tennessee Propane Training Requirements Under PEP — 2026 Guide

ennessee law actually says

Tennessee regulates propane through the Liquefied Petroleum Safety Act of Tennessee, Tenn. Code Ann. Title 68, Chapter 135, Part 1 (§§ 68-135-101 through 68-135-111), administered by the State Fire Marshal's Office inside the Tennessee Department of Commerce & Insurance — Permits and Licenses Unit. The implementing rules are the Liquefied Petroleum Gas Safety Regulations, Tenn. Comp. R. & Regs. 0780-02-17, which also adopt the NFPA 58 / NFPA 54 framework.

The operative pieces:

• § 68-135-103 — qualifications. The applicant (or the person charged with active management of the firm) must be at least 21 and must submit either evidence of at least three years of experience in the liquefied petroleum gas business or evidence of attendance at safety and handling training classes designed and established by the National Propane Gas Association.
• § 68-135-104 — license classes, fees, requirements. Tennessee issues LP-gas dealer licenses in classes covering the different scopes of the business (through Class V); each licensed activity rides on the class held.
• Rule 0780-02-17-.03 — examinations and RMEs. Every licensee designates one Responsible Managing Employee per licensed location, and the applicant and RME (except Class V) must pass a state examination demonstrating adequate knowledge of the fire marshal's regulations. The exam is administered by the state's contracted testing vendor (Morris & McDaniel).
• Employee-level exams at the fire marshal's discretion. The statute and rules let the state fire marshal require that any person, employee, or representative directly engaged in delivering, installing, or servicing LP-gas or LP-gas equipment be examined on the regulations.

The plain read: Tennessee is a confirmed training-pathway-in-law state, but the hook is generic-by-name — "training classes designed and established by the National Propane Gas Association," not the acronym CETP. CETP was the NPGA-created program that language was written for. That generic wording helped when CETP evolved; it raises one clean question now, because PEP is built and issued by PERC, not NPGA. Same industry, different body — and that distinction is exactly the kind of thing a licensing clerk can stick on.

Nationally: PERC is archiving CETP on a rolling basis — each module retires roughly 12 months after its PEP replacement releases. PEP is role-based and modular, the credential is a PERC Learning Center transcript instead of a paper CETP certificate, and the proctored CETP exam is replaced by module knowledge assessments plus OJT worksheets verified by a PEP-Recognized Field Trainer.

For Tennessee, two things matter. First, the training leg: if you've been qualifying license applicants and managers via CETP completion, the document you submit going forward will be a PEP transcript — and the SFMO needs to accept it as the modern equivalent of the "NPGA-designed" classes the statute names. No Tennessee notice has said so publicly, which means the answer lives in a direct written confirmation from the Permits and Licenses Unit. Second, the exam leg doesn't move at all: the Tennessee RME examination is the state's own test on the state's own regulations. PEP module assessments do not replace it, never replaced CETP's role in it, and passing PEP does not exempt anyone from the Morris & McDaniel exam. Operators who conflate the two legs get surprised at renewal or at a new-location filing.

1. Get the PEP question answered in writing. Ask the State Fire Marshal's Office whether a PERC Learning Center transcript showing PEP completion satisfies § 68-135-103's "safety and handling training classes designed and established by the National Propane Gas Association" pathway. Keep the answer with your license file.
2. Keep the three-year-experience pathway in mind. For a seasoned applicant or manager, § 68-135-103's experience leg stands on its own — the PEP question only gates the training leg.
3. Keep your RME chain current. One designated RME per licensed location, exam passed. If an RME leaves, that location has a compliance hole no PEP transcript fills — schedule the replacement's state exam immediately.
4. Keep training on PEP. It's PERC's current program and the successor to the curriculum Tennessee's statute was written around. Whatever the SFMO's paperwork answer, a trained crew is the point of the law.
5. Hold prior CETP certificates. They remain valid records in the PERC Learning Center — and for anyone qualified under the old paperwork, they're the evidence of how the license was earned.
6. Expect employee-level exams to stay on the table. The fire marshal's authority to examine any delivering/installing/servicing employee is discretionary but real. Documented PEP training is your best posture if it's ever invoked.

• The PERC Learning Center transcript for each PEP-trained employee (PEP issues no paper certificate).
• The qualification evidence behind each license — the three-years-experience record or the training-class completion § 68-135-103 required, for the applicant or active manager.
• Each location's RME designation and state exam pass — one per licensed location, and the renewal trail.
• The SFMO's written answer on PEP satisfying the NPGA-clause (the one open item worth a follow-up until you have it).
• Any prior CETP certificates — keep them; they remain valid records in the Learning Center.
• OJT worksheets and who verified them. PERC's Learning Center auto-tracks eLearning only; hands-on OJT is yours to track and retain.