It depends on the jurisdiction, in VA the tenant is considered an "owner" for the purposes of code applications.
From 2012 Virgnia construction Code
"OWNER. The owner or owners of the freehold of the premises or lesser estate therein, a mortgagee or vendee in possession, assignee of rents, receiver, executor, trustee or lessee in control of a building or structure."
PA UCC states "Owner or Authorized Agent" as to who can apply and 2012 IRC defines
"OWNER. Any person, agent, firm or corporation having a legal or equitable interest in the property."
I think that would include a tenant.