Carbon Monoxide Detector Requirements for Tennessee Hotels and Short-Term Rentals

Two Tennessee statutes ask for the same ten feet, and only one of them says how to power the alarm. A hotel existing before that date takes TCA 68-120-112, which makes it unlawful to own or operate a hotel with a fossil-fuel-burning heater or appliance, a fireplace or any other feature emitting carbon monoxide as a byproduct of combustion without an approved alarm within ten feet of each room used for sleeping. One constructed on or after it takes TCA 68-120-101(a)(10), same ten feet, and the alarms are hardwired to the building's power supply with secondary battery backup.

Last verified: August 24, 2026

Key Takeaways

Short-term rental providers carry the hotel owner's maintenance and operational obligations. TCA 68-120-112(d)(2) does that, as extended by the Tennessee Short-Term Rental Unit Act of 2018.
Knoxville prints a looser number than the statute, and an operator who reads only the city form will get it wrong. Section 16-612(2) asks the affidavit of life safety compliance to list a carbon monoxide detector within fifteen feet of all bedrooms, where the statute says ten. The affidavit also lists a smoke alarm inside each sleeping room and on every storey including basements, and a fire extinguisher. Every device has to sound on its test button, the affidavit states the number, location and working order of each one, the equipment is subject to verification or inspection, and operating without any of the three is unlawful in itself.
Memphis counts floors where the statute counts sleeping rooms. Section 5-44-6(C) puts approved carbon monoxide detectors on every habitable floor of every registered short-term rental, with no fuel trigger and no distance in it, so a three-storey house needs three where the statute might ask for one. The duty rides on the permit, and Section 5-44-7 revokes that permit after three court findings of violation.
The three towns holding most of Tennessee's cabin market ask for nothing of their own. Gatlinburg, Pigeon Forge and Sevierville each leave the question to the statute, on indexes answering 310, 196 and 151 times for "building" and 152, 164 and 160 for "fire" while returning nothing at all for carbon monoxide.
Nashville and Chattanooga read like findings on a raw count and are not. Nashville's two carbon monoxide provisions are an air quality permit fee and an ambient standard of 35 parts per million, and eight of Chattanooga's nine are air pollution measurement procedures.

Legal Summary

Tennessee imposes carbon monoxide alarm requirements on hotels and short-term rentals through two complementary statutory provisions. For hotels existing before January 1, 2016, TCA § 68-120-112 makes it unlawful to own or operate a hotel that has a fossil-fuel-burning heater or appliance, a fireplace, or any other feature that emits CO as a byproduct of combustion, without installing an approved CO alarm within ten feet of each room used for sleeping purposes. For hotels constructed on or after January 1, 2016, TCA § 68-120-101(a)(10) requires CO alarms within ten feet of each sleeping room in hotels with qualifying CO sources, and mandates that alarms in new construction be hardwired to the building's power supply with secondary battery backup.

Short-term rental providers are explicitly subject to the maintenance and operational obligations that apply to hotel owners under TCA § 68-120-112(d)(2), as extended by the Tennessee Short-Term Rental Unit Act (SB1086, 2018).

Who Is Covered

Tennessee's CO alarm law covers hotels broadly. Under TCA § 68-120-112, "hotel" is defined to include any building providing sleeping accommodations for guests, travelers, or semi-permanent residents for commercial purposes, including motels, inns, boarding homes, lodging homes, rooming houses, tourist homes, hostels, dormitories, and apartment hotels. The trigger is the presence of a fossil-fuel-burning heater or appliance, a fireplace, an attached garage, or any other feature that emits CO as a byproduct of combustion.

Short-term rental providers, as defined under TCA § 67-11-101, are separately covered by the SB1086 amendment to § 68-120-112(d)(2), which assigns STR providers the same maintenance and operational responsibility as hotel owners. STRs are defined to exclude traditional hotels and motels under Tennessee law.

Hotels already standing: covered too. The Tennessee requirement reaches an existing hotel and not only one being built.

Operator Responsibilities

Hotel owners and managers in Tennessee carry two distinct obligations under TCA § 68-120-112. First, installation: it is unlawful to operate a hotel with any fossil-fuel-burning appliance, fireplace, or CO-emitting feature without an approved CO alarm installed within ten feet of each sleeping room. This applies to all hotels existing before January 1, 2016, regardless of when the property was built. Second, maintenance: TCA § 68-120-112(d)(2) places affirmative responsibility on the hotel owner or manager to ensure that every required CO alarm is operational at all times, including all maintenance, repairs, and tests necessary to keep alarms functional.

For new hotel construction begun on or after January 1, 2016, TCA § 68-120-101(a)(10) requires CO alarms within ten feet of each sleeping room in hotels with qualifying CO sources, and mandates that these alarms be wired directly to the building's power supply with secondary battery backup.

Short-term rental providers are subject to the same maintenance, repair, and testing obligations as hotel owners under TCA § 68-120-112(d)(2), as extended by SB1086 (2018). STR providers must ensure that CO alarms are operational at all times where required.

All required CO alarms must comply with ANSI/UL 2034 or ANSI/UL 2075 and be installed per NFPA 720 or NFPA 72 standards. Combination smoke/CO alarms are permitted, provided they comply with ANSI/UL 2034 or ANSI/UL 2075 for CO and ANSI/UL 217 for smoke, and differentiate audibly between CO and smoke alerts.

Installation and Technical Requirements

Under TCA § 68-120-112(b)(1), all CO alarms must be installed within ten feet of each room used for sleeping purposes, in accordance with the manufacturer's directions and applicable law. For hotels existing before January 1, 2016, approved power configurations include: wired directly to the building's power supply; powered by a self-monitored battery; or operated with a plug-in outlet fitted with a plug restrainer device, provided the outlet is not controlled by any switch other than the main power supply.

For hotels constructed on or after January 1, 2016, TCA § 68-120-101(a)(10)(B) requires that CO alarms be wired directly to the building's power supply with secondary battery backup, battery-only installation is not permitted in new hotel construction.

All devices must comply with ANSI/UL 2034 or ANSI/UL 2075. CO alarms must be installed in accordance with either NFPA 720 or NFPA 72 standards. No alarm silencing switch or audible trouble silencing switch may be provided unless its silenced position is indicated by a readily apparent signal.

Enforcement

Enforcement of TCA § 68-120-112 is governed by § 68-120-106 and is carried out by the Tennessee State Fire Marshal's Office. The State Fire Marshal enforces statewide standards and has authority over all buildings subject to these provisions. Local governments in Tennessee may adopt and enforce their own building construction and fire safety codes consistent with TCA § 68-120-101(b), but only if they certify in writing to the State Fire Marshal that they have done so. The State Fire Marshal audits local enforcement programs at least every three years and may resume direct enforcement if a local program is found to be inadequate. Compliance with TCA § 68-120-112 does not relieve any person from requirements of other applicable laws, ordinances, or rules.

Penalties

Under TCA § 68-120-112(e)(1), a violation of the section is a Class C misdemeanor. Each day on which a violation continues constitutes a separate offense. Enforcement procedures are governed by TCA § 68-120-106, which gives the State Fire Marshal authority to pursue corrective action. A Class C misdemeanor is the lowest of Tennessee's three misdemeanor classes, and TCA § 40-35-111(e)(3) fixes it at not greater than thirty days or a fine not to exceed $50, or both, unless the defining statute says otherwise. Section 68-120-112 classifies the offense and stops there, so the $50 governs. The per-day rule is what makes the figure bite: fifty dollars is a rounding error, and fifty dollars for every day a guest room sits uncovered is not. Knowingly tampering with or removing a required CO alarm is also unlawful under TCA § 68-120-112(b)(4) and is subject to the same criminal penalty provisions.

Local Override Warning

Tennessee local governments may adopt and enforce their own building construction and fire safety codes under TCA § 68-120-101(b), which can include CO alarm requirements for hotels and STRs more specific than the statewide baseline, and the State Fire Marshal may resume direct enforcement if a local program proves inadequate. Two cities have used the power and both aimed it at short-term rentals rather than hotels. Memphis Section 5-44-6(C) requires a detector on every habitable floor of a registered short-term rental. Knoxville Section 16-612(2) requires a sworn affidavit listing a detector within fifteen feet of all bedrooms, a smoke alarm inside each sleeping room and on every storey, and a fire extinguisher, and makes operating without any of the three unlawful. Gatlinburg, Pigeon Forge and Sevierville, which between them hold most of the state's cabin market, add nothing at all: their codes were read in full through the Municipal Technical Advisory Service and return zero for carbon monoxide against live counts for building and fire. Nashville and Chattanooga likewise. A hotel operator in Tennessee is on the statute in all seven.

Frequently Asked Questions

Are carbon monoxide detectors legally required in Tennessee hotels?

Yes. Under TCA § 68-120-112(b)(3), it is unlawful to own or operate a hotel that has a fossil-fuel-burning heater or appliance, a fireplace, or any other feature that emits CO as a byproduct of combustion, without installing an approved CO alarm within ten feet of each sleeping room. This rule applies to all hotels existing before January 1, 2016. For hotels built or substantially renovated on or after January 1, 2016, TCA § 68-120-101(a)(10) imposes the same 10-foot placement standard and additionally requires alarms to be hardwired to the building's power supply with secondary battery backup.

Does Tennessee law require CO alarms in Airbnb and short-term rental units?

Yes, through the Tennessee Short-Term Rental Unit Act (SB1086, 2018), which amended TCA § 68-120-112(d)(2) to extend the hotel owner's maintenance responsibility to short-term rental providers. Under this provision, an STR provider, as defined by TCA § 67-11-101, is responsible for all maintenance, repairs, and tests necessary to ensure that every required CO alarm in the unit is operational at all times. This maintenance obligation mirrors the duty placed on hotel owners and managers under the same statutory subsection.

Who is responsible for maintaining CO alarms in a Tennessee hotel or STR?

Under TCA § 68-120-112(d)(2), the owner or manager of a hotel is responsible for all maintenance, repairs, and testing needed to keep every required CO alarm operational at all times. This is an affirmative, ongoing duty, not limited to initial installation. The 2018 SB1086 amendment extended this same obligation to short-term rental providers. Unlike the residential apartment building rule, where tenants maintain their own unit's smoke alarms, hotel and STR operators bear the full maintenance responsibility throughout the occupancy period.

What is the penalty for not having required CO alarms in a Tennessee hotel?

Under TCA § 68-120-112(e)(1), a violation is a Class C misdemeanor in Tennessee. TCA § 40-35-111(e)(3) fixes that class at not greater than thirty days or a fine not to exceed $50, or both, and because 68-120-112 classifies the offense without setting its own figure, the $50 governs. Each day on which a violation continues constitutes a separate offense, so a hotel operator who remains non-compliant over multiple days faces the fifty dollars again for every one of them. Enforcement is conducted by the Tennessee State Fire Marshal's Office under TCA § 68-120-106. Knowingly tampering with or removing a required CO alarm also constitutes a violation under § 68-120-112(b)(4) subject to the same criminal penalty.

Where exactly must CO alarms be placed in Tennessee hotel rooms?

Under TCA § 68-120-112(b)(1) and § 68-120-101(a)(10), CO alarms must be installed within ten feet of each room used for sleeping purposes. This distance is measured from the alarm to the entrance or sleeping area of the room, consistent with manufacturer's directions and applicable law. Alarms must comply with ANSI/UL 2034 or ANSI/UL 2075, and be installed in accordance with either NFPA 720 or NFPA 72 standards. Combination CO and smoke alarms are permitted, provided they comply with device listing standards and audibly differentiate between CO and smoke alerts.

Can Tennessee cities impose stricter CO alarm requirements on hotels?

Yes, with conditions. Under TCA § 68-120-101(b), local governments may adopt and enforce their own building construction and fire safety codes if they certify in writing to the State Fire Marshal that they have done so and that their codes meet minimum standards. Local codes can include CO alarm requirements for hotels that are more specific than the statewide minimum. The State Fire Marshal audits local programs at least every three years and may resume direct enforcement if a local program is found inadequate. Operators should verify current requirements with their local building department or fire marshal.

Disclaimer: This page explains the law as it stood on August 24, 2026. It is general information, not legal advice, and reading it creates no attorney-client relationship. Requirements vary by city, county and building type, and statutes and codes are amended: confirm the current text with the issuing authority before acting on it. Each requirement here cites the instrument it comes from, so you can check it at source.

Sources and References

TCA § 68-120-112, Smoke alarms and carbon monoxide alarms in residential buildings (FindLaw mirror of Tennessee Code Annotated) , § 68-120-112(b)(3), hotel CO alarm within 10 feet of sleeping rooms; § 68-120-112(c)(3), applies to buildings existing before Jan 1, 2016; § 68-120-112(d)(2), hotel owner/manager maintenance obligation; § 68-120-112(e)(1), Class C misdemeanor penalty; § 68-120-112(a), definitions (hotel, fossil fuel, CO alarm)
TCA § 68-120-101, Building construction safety standards (FindLaw mirror of Tennessee Code Annotated) , § 68-120-101(a)(10)(A), CO alarm within 10 feet of sleeping rooms in new hotel construction with CO sources (on or after Jan 1, 2016); § 68-120-101(a)(10)(B), hardwired with secondary battery backup required for new construction; § 68-120-101(b), local government enforcement authority
Tennessee Short-Term Rental Unit Act, SB1086 (2018), amending TCA § 68-120-112(d)(2) , Section 10, STR provider as defined by § 67-11-101 is responsible for maintenance, repairs, and tests to ensure CO alarms required under § 68-120-112 are operational at all times
TCA § 68-120-106 and TCA § 40-35-111(e)(3), Enforcement authority and Class C misdemeanor fine range (FindLaw mirror of Tennessee Code Annotated) , § 68-120-106, State Fire Marshal enforcement procedures; § 40-35-111(e)(3), Class C misdemeanor punishable by not greater than thirty days or a fine not to exceed $50