With Kari’s Law and RAY BAUM’S Act in force, it is critical that all organizations verify their compliance with these laws.

While participating in the 2022 Enterprise Connect annual conference panel on Managing E911 for Compliance and Safety, Martha Buyer, an attorney who was involved with the creation of Kari’s Law, stated, “Enterprises that operate multi-line telephone systems, and have either installed new systems or completed a major upgrade since February of 2018, don’t really have an excuse for non-compliance that would likely hold up in court. There are other areas of state and federal laws that if not specifically requiring compliance, suggest that non-compliance is a bad place to be. Specifically, OSHA regulations require organizations provide a safe workplace. It would not be a tough argument to make in court that anything that could be construed as denial to access of 911 absolutely creates an unsafe workplace.”

How does your organization comply with these new laws? It is in every organization’s best interest to verify full compliance with these laws. Besides the precedent of a large award for the wrongful death of Kari Hunt Dunn, with these laws, there is also the potential of daily fines.  “Law requires reasonable efforts to be compliant.” states Buyer.

Who needs to be compliant? It makes good business sense to update your phone systems to meet the requirements of these laws. Kari’s Law requires that there is no pre-fix needed for outbound calls to 911. Part of the $42 million settlement was awarded from the hotel owner, OM Lodging, LLC as a result of the neglect of proper configuration of the MLTS. For specific information on compliance, refer to this FCC site:  https://www.fcc.gov/mlts-911-requirements.

Also, with every 911 call, notifications MUST be sent to a department or persons onsite responsible for safety to inform them about the incident. When 911 call notifications are received, it is recommended that personnel be sent immediately to the place of the emergency to provide aid until the first responders arrive. Personnel should be sent to the site entrance to meet the emergency responders when they arrive to expedite their ability to find the person in distress.

RAY BAUM’S Act adds requirements that dispatchable location information is sent to the local public safety answering points (PSAP). To simplify, a call to 911 must provide dispatchable location information including addresses 1 & 2 where address 1 is the physical street address, and address 2 provides the internal location like suite/room/floor information to assure the person calling can be found quickly by the first responders. The law requires MLTS systems must have enabled this 911 functionality where available, and it must be implemented and maintained. This law requires full compliance by the MLTS manufacturers, distributors, and users of the MLTS since January 2022.

Remote workers and wireless devices are now included in the 911 laws as of January 2022. This has become extremely important in a post-pandemic “work from anywhere” workplace where the physical location of workers may change daily. According to Managing E911 for Compliance and Safety panelist Mark Fletcher, VP Public Safety Solutions for 911inform, LLC and co-author of Kari’s Law, “240 million 911 calls a year, that’s 85% of all 911 calls, are made from mobile devices.”

Buyer also noted that although there may be a small number of organizations that do not fit under the requirements of these two E911 laws, all organizations are required to “provide a safe workplace” under OSHA regulations.

Verification of compliance requires due diligence. It can seem like an insurmountable project to begin. Following are recommendations for getting started on compliance and how to test 911 calls.

Here are ideas to get you started:

• Determine what devices or systems for your organization fall under these laws. Use the basic rule if a device can be used to make an outside call, it should be compliant.
• Develop internal policies to ensure 911 use and regulatory compliance.
• Establish procedures for setup and maintenance. Test often and routinely like other safety procedures and equipment.
• Meet with first responders to determine what they require to help someone in need of emergency assistance at your locations.

How to test 911 calls:

Your first step in testing 911 calls is to identify your PSAP for your business locations. Use this link to determine the local PSAP for your locations. Coordinate with local first responders/PSAP when test calls will be made which are not emergencies.

Second, make test calls to determine what information is sent to the PSAP. Call 911 from every location (site, building, etc.) and record data of what the PSAP receives. This includes the telephone number (TN) displayed, the address displayed, the caller name displayed, and PSAP where the call was routed. 

Third, ensure the phone system is configured properly. Verify latest 911 functionality is enabled and configured. Verify the TNs associated with the correct location HUB as provisioned. 

Fourth, work with the supplier and CPE vendor to make any necessary corrections. This may include correcting the Caller ID information sent out, and changing incorrect service address information – Address 1 & 2. 

Finally, test again until compliance is verified.

There is a sample questionnaire available for download to use for making test calls and tracking information.

This is not meant to be a comprehensive testing procedure, only a starting point for crafting a test procedure that best helps your organization meet compliance. Education is key to make employees, contractors, customers, visitors, etc. aware of the process for dialing 911. It’s also important to understand the limitations of the technology. There still needs to be a human element to ensure the proper help is sent to the person in distress.

Organizations should enlist the help of a communications technology consultant to manage projects to verify compliance which includes a first-time verification process and follow up verifications annually or when major changes are made to a MLTS or within your organization. These procedures should become part of the internal safety and disaster plan that is tested and maintained annually.

Our industry has been inundated with news about the demise of POTS (Plain Old Telephone Service) lines. Recently, the FCC issued a new order with the goal of abandoning the rapidly deteriorating copper wiring infrastructure throughout the US. Through this order, the FCC is allowing Local Exchange Carriers (LECs) to stop providing analog POTS services.

Carriers now have the option to stop providing these services while being allowed to increase the price those services. We’ve seen carriers announce “end of life” plans for their services in the next year and carriers raise the rate for a single analog phone line to quadruple the monthly rates as an enticement to move to IP-based communications using their fiber or cellular networks.

From a carrier perspective, there are many reasons to move customers away from the legacy copper services. The carrier equipment to support those services is old – difficult and expensive to maintain. The workforce that supports this equipment is retiring and not being replaced. In addition, it is expensive to put copper in the ground.

Services that you most likely are using POTS for include things like: fax machines, fire alarms, elevators, and security alarms. These services may not be at the top of your technical project list, but they are critically important to your organization. These services may not be forced to be replaced right away, but the cost will rise significantly, and you may not be able to get the services in the future from your provider.

Now is the time to plan. There are solutions that can be deployed to replace those lines – driven by your schedule and requirements.

For a guide to help you through the maze of issues and options – give us a call or reply back to this email.