For the last several years I’ve been fortunate to moderate a session at Enterprise Connect focusing on enterprise challenges in managing E911. This year, with two new federal regulations about to go into effect, our annual session takes on an even greater importance for those responsible for telecommunications infrastructure, applications, and services.
Reducing Trouble Issues
The first of these new regulations is Kari’s Law. Signed into law in February 2018, Kari’s Law stemmed from the tragic story of Kari Hunt Dunn. In 2013, Kari’s estranged husband attacked her at a motel in Texas in front of her three young children. One of her children knew to call 911 in an emergency, but was unable to reach first responders because the hotel’s phone system required first dialing a “9” to reach an outside line.
Thanks to the efforts of Kari’s father Hank and Mark Fletcher, chief architect of Avaya’s public safety solutions, Kari’s Law will increasingly ensure that anyone can pick up a landline phone anywhere and dial 911 directly without the need to first dial an extra digit.
Kari’s Law requires that entities that manufacture, import, sell, lease, and/or install systems after Feb. 16 must be compliant with Kari’s Law. That is, when installing a premises-based or hosted system that operates as a multiline telephony system (MLTS), an enterprise must ensure that the system:
- Allows for direct dial of 911 without having to first dial a prefix to reach an outside line
- Provides notification, with call location information, to either a security station at the facility from where the call originates, or to another person or organization
- Requires that 911 calls are routed to a certified public safety answering point (PSAP) and cannot be intercepted
As noted, all new MLTS implementations after Feb. 16 must comply
with Kari’s Law. However, the law does not require organizations to ensure compliance for existing systems. But because failure to bring existing systems into compliance may create risk, you would be wise to consult your legal counsel and determine a proper forward path.
The second new regulation is the “Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018,” or RAY BAUM’S Act, named after Ray Baum, the late Oregon state representative. Baum worked with the Federal Communications Commission (FCC) on telecommunications issues while serving on the staff of Oregon Rep. Greg Walden.
RAY BAUM’S Act amends the Communications Act of 1934 to reauthorize appropriations for the FCC. As part of this reauthorization, Section 506 of the law and subsequent FCC rulemaking require that phone systems transmit 911 calls to the appropriate PSAP with “dispatchable location” information. As defined in the law, dispatchable location is: “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.” In a typical office environment, this could include building, floor, wing, office, cubicle, or other location information allowing first responders and in-building security personnel to know the exact location of the person calling 911.
RAY BAUM’S Act goes into effect for fixed-line operators on Jan. 6, 2021, and for mobile operators on Jan. 6, 2022.
Assessing the Implications
RAY BAUM’S Act federalizes regulations that have been in place in many states, and as such, organizations operating within states with existing regulations are likely to be compliant already. Kari’s Law, on the other hand, is an entirely new federal regulation that requires telecom managers to ensure that their planned new systems or services are compliant.
In addition to these new federal regulations, many organizations have additional needs such as:
- Misdial prevention to eliminate inadvertent 911 calls
- Logging and recording of calls for future analysis or to support legal proceedings
As organizations move to ensure regulatory compliance, they must do so while operating in an environment where the shift to softphones and wireless workers, as well as mixed-vendor telephony environments, means that tracking location is increasingly difficult, at least until Next Generation 911 (NG911) solutions are widely available — hopefully in the near future.
Unfortunately, ensuring 911 compliance doesn’t typically provide a quantifiable return on investment or reduce operating costs, so for many organizations, compliance efforts suffer from a lack of IT prioritization. As I’ve mentioned in past Enterprise Connect sessions, E911 is one of the few areas of unified communications with life and death implications. Failure to ensure compliance at a minimum opens a company up to regulatory violations and added risk. At the maximum, it may result in individuals not being able to obtain potentially life-saving emergency services in response to a safety or health situation.
IT leaders must take a proactive approach to ensuring Kari’s Law and RAY BAUM’S Act compliance. Work with your telephony, PSTN access, and 911 management providers to assess what must be done in the short and long terms, and stay abreast of growing availability of NG9-1-1 solutions that will improve real-time location management and reporting.
Thank you to fellow No Jitter contributor Martha Buyer for assistance with this post.