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911 Compliance Doesn’t Come Shrink Wrapped
Telecommunications platform and provider professionals have spent the last few years getting up to speed with new federal regulations for 911 emergency service. As of February 16, 2020, any new telecommunications platform or solution sold in the United States was required to comply with Kari's Law; and as of January 6, 2021, those platforms were also required to comply with RAY BAUM's act. (You can read an overview of these two laws' requirements here.) The Federal Communications Commission (FCC) set deadlines for manufacturers, importers, and sellers of multi-line telephone systems (MLTS) to ensure that products and services are compliant with the two laws.
Kari's Law requires any multi-line telephone system to enable direct dialing of 911 without needing an additional prefix, such as "9," to obtain an outside line. RAY BAUM's Act requires any multi-line telephone system to provide accurate information about the physical location of the caller to emergency services, known as the "dispatchable location." These laws include additional provisions such as simultaneous notification to a staffed location and call back number.
However, as with any technology, the functional capabilities are only part of the overall solution. Factors such as the overall quality of location data and procedures that optimize the communications system's capabilities are important in successfully deploying 911 notification. Your vendor may check off all the boxes to comply with FCC regulations, but in a real-world enterprise, one size does not fit all.
Stress Test Compliance By Visualizing Emergencies
The goal in planning 911 compliance should be to ensure true organizational or campus safety. You should review potential emergency scenarios and envision the process, from the calling party to the dispatched responders. Does the calling party have the correct instructions to dial 911 and to relay location information to the Public Safety Answering Pont (PSAP)? What data is displayed with the call at the PSAP? There may be character limitations at the PSAP, so if the granular floor or building data is too long, it may not be displayed.
Equally important is visualizing what emergency responders will see. You may have addresses such as “1250 Devonshire St.”, but every sign on your campus and the building itself indicates it is “The Arts Complex,” not Devonshire St. Many industrial facilities are gated, requiring any outside parties to be escorted by corporate security. In some cases, the official street address may be different from the common public entrance into a building. Plan for how to address these conditions before anyone has cause to make a 911 call.
Review How Technical Capabilities Can Meet Your Unique Criteria
MLTS 911 and third-party 911 notification systems are designed to comply with Kari's Law and the RAY BAUM's Act, but each will have a unique set of capabilities and limitations. If you are doing your planning prior to selecting a system, you can use the unique criteria of your environment to evaluate how well different solutions will fit.
For example, when an emergency call is made from a phone, the system will automatically notify designated contact points in the organization, such as the security office, and must include dispatchable location information. The law itself does not dictate a specific channel for notification, but gives examples, “Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators.”
It is up to the customer to determine the following:
- Is the notification- timely or conspicuous enough?
- Is it going to a system that is constantly monitored?
- If it is email, are there delays or filters that would make the notification ineffective?
- Whether email, text, or a wallboard, could the notification be overlooked because of twenty other non-emergency communications that are sent to the same screen?
Some 911 notification systems can be customized to specify the number and types of notifications, and the integration with other emergency systems which should include the address information displayed to the PSAP. In security sensitive organizations, there may be a value in having 911 notification integrated into larger security and safety systems, which can include alarms, marquees and even lockdown mechanisms.
Identify Limitations to Technology
Is it ever possible to be compliant with 911 regulations straight out of the box? Maybe, if you have a single-address office with clear demarcations of every floor, each network switch serving a specific area, no wireless devices and little to no network or telecom moves. Technical limitations are a result of multiple factors, including the system itself, your facilities, cellular capabilities and even the local PSAP.
Location accuracy is based on up-to-date records, and different systems have unique tools for keeping locations up to date. Switch and gateway locations or known IP (Internet Protocol) addresses are a good method of keeping track of moving IP endpoints, but if you have a complex LAN environment, with switches that serve multiple dispatchable locations, you may need to use a combination of automatic and hard-coded updates. Wi-Fi overlap is typical in an office or campus environment, with the benefit of uninterrupted data connectivity. This same overlap can cause devices to register on a wireless access point that is reported as a different dispatchable location from actual location of the endpoint.
On the service provider side, cellular towers do not always report an accurate location for a mobile device, even with 80% of 911 calls originating from a cellular phone. In our testing we have seen devices report addresses as far as 3/4 of a mile away from the actual location! A recent report in the Federal Register noted that
“Wireless 911 calls have historically been routed to PSAPs based on the location of the cell tower that handles the call. Sometimes, however, the 911 call is routed to the wrong PSAP because the cell tower is not in the same jurisdiction as the 911 caller. This can happen, for instance, when an emergency call is placed near a county border.”
The eventual goal for Next Generation 911 (NG911) is to have all calls and texts to a PSAP identified by GPS (Global Positioning System) coordinates, addresses and even landmarks, but currently there are varying levels of compliance.
While local PSAPs (Public Safety Answering Points) are standardizing on NG911, this too is a work in progress. There are many standards for PSAP centers, products, information sharing and operational practices. Much like on the enterprise side, a PSAP’s subscription to a NG911 platform is only one step in the process; there will be many dependent systems and processes which also require upgrades.
Identify Risks and Build Your 911 Compliance Plan
Identifying areas and levels of risk is an important part of your 911 planning. This involves looking at everything related to 911 and includes non-technical details such as end user instructions and building signage. Dispatchable locations should be mapped to an entry point that first responders can access. Your notification system must be able to immediately and conspicuously notify appropriate support staff not just that an emergency call has been placed, but its location as well. Your operational guides should have a clear process for updating location data, and your onboarding process should include clear instructions on 911 capabilities and limitations (note: Instructing callers to never call 911 from a VoIP (Voice over IP) phone is not a compliant procedure). Identify risks by identifying any gaps in these processes, such as ambiguous network areas and work areas with no clear entry point. A good practice for identifying the level of risk is to envision how much delay could be caused by any misinformation or lack of access to an emergency.
In the end, remember the goal is the safety of the members of your organization. The process to accomplish this may be complex, but it could be one of the most important plans you make for your enterprise.
Note: The authors will be addressing 911 planning and compliance testing at Enterprise Connect Orlando on March 29 with the session: Ensuring E911 Compliance with a Comprehensive Audit.
Enterprise Connect 2023 will be held from March 27-30 at the Gaylord Palms in Orlando, FL. You can check out the attendance options here and dive into our line-up of sessions and keynotes here.