Three weeks ago, the owner of a small security company in East Memphis told me he had eleven open positions and zero qualified applicants. Not zero applicants. Zero qualified applicants. The distinction matters.
His problem isn’t that people don’t want the work. Plenty do. His problem is that the state of Tennessee requires every security guard to complete a 16-hour unarmed training course before they can legally stand post. And right now, those training courses aren’t happening.
COVID-19 has done what no regulation or market downturn could: it has ground the Tennessee guard licensing pipeline to a near halt. The Tennessee Department of Commerce and Insurance, which oversees private protective services through its regulatory board, has watched training providers cancel classes, reduce capacity, and in some cases shut down entirely since March. The backlog this created is now slamming into the worst possible market conditions. Memphis businesses want more guards. They can’t get them.
What the Law Actually Requires
Tennessee’s Private Protective Services Licensing and Regulatory Act, codified under T.C.A. 62-35, lays out clear requirements for anyone working as a security guard in the state. The basics haven’t changed in years. Every unarmed guard must complete 16 hours of state-approved training covering legal authority, report writing, emergency procedures, and ethics. Armed guards need that same 16 hours plus a separate 12-hour firearms training course under T.C.A. 62-35-118, which includes four hours on legal limitations of firearm use, three hours of weapons handling, and live-fire qualification.
These aren’t optional. A security company that puts an untrained guard on a post is violating state law, risking its company license, and exposing itself to massive liability. Every reputable operator in Tennessee knows this.
The system worked fine when training providers held regular classes across the state. Nashville had multiple providers running weekly sessions. Memphis had several. Knoxville and Chattanooga each had a couple. A prospective guard could typically get trained and registered within two to three weeks of applying.
That timeline is gone.
The COVID Training Bottleneck
When the pandemic hit Tennessee in March, training providers faced the same impossible math as everyone else. The 16-hour unarmed course typically runs in a classroom setting with 15 to 30 students. Social distancing rules cut that capacity in half overnight. Some providers couldn’t make the economics work at eight students per class and stopped scheduling entirely.
The armed training component is even harder to adapt. Live-fire qualification requires range time. Several ranges in the Memphis area restricted access or closed temporarily during the spring surge. Even now in October, range availability is tighter than normal, and some instructors who are older or have health conditions have stepped back from teaching.
TDCI explored virtual training options earlier in the year. The problem is that much of the required curriculum involves hands-on components that don’t translate to a Zoom call. You can teach legal authority online. You can’t qualify someone on a firearm through a laptop screen. The department approved some limited virtual instruction for the classroom portions, though the practical and firearms elements still require in-person attendance.
Background check processing has slowed too. The Tennessee Bureau of Investigation handles the criminal history checks that TDCI requires for guard registration. TBI, like every state agency, has been operating with reduced staff and adjusted procedures since spring. What used to take a week or two now sometimes stretches past a month.
Small Companies Are Getting Crushed
Here’s where the shortage gets uneven. National firms like Allied Universal and Securitas have a structural advantage that no amount of hustle can overcome: they operate across dozens of states and can transfer licensed guards between regions.
If Allied Universal needs 20 more guards in Memphis next week, they can pull from their operations in Nashville, Little Rock, Jackson, or Birmingham. Those guards are already trained, already background-checked, already on payroll. The company eats some travel costs, maybe puts people up in hotels for a few weeks, and the client never knows the difference.
A Memphis company with 40 guards and contracts across Shelby County can’t do that. When they lose three guards to turnover in the same month (which happens all the time in this industry), they’re staring at a six-week gap before replacements can get through training and registration. Six weeks of overtime, six weeks of burning out the guards they still have, six weeks of hoping the client doesn’t notice thinner coverage.
I talked to four small and mid-size security company owners in the Memphis area over the past two weeks. Every single one described the same pattern. They’re turning down new contracts because they can’t staff them. They’re losing existing guards to nationals who offer signing bonuses. And they can’t replace those guards fast enough because the training pipeline is clogged.
One owner on Summer Avenue put it bluntly: “I’ve got a stack of contracts I could sign tomorrow. I physically do not have the people.”
The Demand Side Won’t Wait
The timing of this shortage is brutal. Memphis is in the middle of its most violent year on record. The city passed 228 homicides by late September, breaking the previous record set in 2016 with three full months still left in the year. MPD Director Michael Rallings has been vocal about the spike, and the department is stretched thin.
When police resources get strained, private security demand rises. That’s a pattern that plays out in every major city during crime surges. Property managers, retail chains, hospitals, and event venues all start looking for more guard coverage. Some are hiring security for the first time. Others are increasing hours or adding armed positions.
COVID enforcement adds another layer of demand that simply didn’t exist a year ago. Businesses need people at the door checking temperatures, monitoring mask compliance, enforcing capacity limits. Grocery stores, restaurants, gyms, churches. The list keeps growing. Many of these employers don’t want to pull their own staff off revenue-generating work to play mask enforcer, so they hire security.
And the holiday retail season is about to start. Every Wolfchase Galleria, every Oak Court Mall, every shopping center along Germantown Parkway will need seasonal security bumps. That’s been true every year. This year they need it while also staffing COVID screening stations and managing crowds that are already on edge from months of pandemic stress.
What TDCI Could Do (and What It Probably Won’t)
Some states have issued emergency provisions to speed up guard licensing during the pandemic. A few have allowed temporary permits that let new hires work under direct supervision while their training and background checks are completed. Others have extended renewal deadlines so existing guards don’t lapse while waiting for continuing education classes that got canceled.
Tennessee hasn’t gone that far. TDCI has been cautious, which is understandable given the liability concerns. Put an untrained guard on a post and something goes wrong? The state agency that allowed the shortcut owns part of that outcome.
Still, there’s a middle ground between full normal requirements and no accommodation at all. Allowing supervised provisional status for applicants who’ve completed the classroom portion of training while they wait for range time would help. Expediting background checks through additional TBI resources would help. Increasing the number of approved training providers, even temporarily, would help.
The Private Protective Services board is aware of the problem. Whether awareness translates to action before the shortage gets worse is another question entirely.
The Uneven Recovery Ahead
Not every company will survive this bottleneck the same way. The nationals will be fine. Allied Universal just completed its merger with G4S, making it the largest security company on the planet. They have recruiting infrastructure, training academies, and enough financial cushion to absorb short-term losses while they transfer staff and ramp up hiring.
Securitas has similar resources. So does GardaWorld. These companies can afford to wait out a licensing bottleneck because they have thousands of active guards spread across the country.
For a company with 25 or 50 guards operating solely in the Memphis metro, this bottleneck is an existential threat. Lose enough contracts because you can’t staff them and you might not recover. The clients you lose won’t come back when the pipeline reopens. They’ll already have signed with someone who could deliver.
The irony is thick. Tennessee’s licensing requirements exist to ensure quality and public safety. Nobody serious in this industry wants untrained guards working armed posts. The requirements are good policy. The failure isn’t in the rules themselves. It’s in the state’s inability to keep the training system running during a crisis that has made trained guards more necessary than ever.
Memphis needs more guards on the street right now. The system that produces them is running at maybe 40% capacity. Something has to give, and so far, it’s the small operators and the clients who depend on them.
Every week the bottleneck continues, the gap between demand and supply gets wider. And we’re heading into a holiday season that promises to test every security operation in the city.