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New 911 Regulations: Yes, These Apply to Your Organization

Compliance for Kari’s Law and RAY BAUM’S Act, newly enacted 911 regulations, is mandatory for any business that uses a phone system with more than one phone line. Failure to comply could result in legal liabilities, yet many organizations aren’t aware of their responsibilities.
Are you?
The questions below will help you assess how ready your organization is to meet the requirements of Kari’s Law, which went into effect on Feb. 16, and RAY BAUM’S Act, which goes into effect on Jan. 6, 2021.
Does this apply to my organization?
Yes, RAY BAUM’S Act applies regardless of the technology platform in use. Meantime, Kari’s Law applies to phone systems manufactured or installed after the regulation took effect on Feb. 16.
What is my potential liability?
Even if your phone system was made or installed before Feb. 16 (and therefore technically not subject to Kari’s Law requirements), you may still risk liability if it doesn’t provide the capabilities required by Kari’s Law, Martha Buyer, telecom attorney and 911 expert, told me.
“Employers have an absolute obligation to provide a safe workplace,” Buyer said.
“It wouldn’t even take a great lawyer to make a strong argument that the absence of access to accurate and reliable 911 information creates an unsafe workplace, thus placing significant liability on employers who have chosen, for any number of reasons (some of which might even be legitimate) not to take the reasonable steps necessary (here, ‘reasonable’ is a legal term of art) to ensure a safe workplace,” she added.
Organizations should work with first responders to determine what information the responder will find most useful in an emergency, when seconds count, Buyer recommended.
And again, as stated above, when RAY BAUM’S Act goes into effect in January, it will apply regardless of technology platform in use.
What if we have offices in multiple states?
Some states have passed laws requiring varying levels of detail about the location of someone placing a 911 call. If an employer is complying with the requirements in one state, it must take the steps necessary to provide sufficiently and similarly detailed information in all states where employees are located, regardless of the requirements of those states, Buyer said.
And, of course, all states are subject to the new federal requirements.
Who should be involved in figuring this out?
Decisions about managing 911 location information should be expanded beyond the IT and communications departments to include representatives from areas such as risk management, legal, finance, and facilities (or any other departments that will bring useful ideas to the table), Buyer recommended. In this context, the more departmental input, the more likely the outcome will reflect the input of those who may be most critically affected.
What else is coming?
RAY BAUM’S Act comprises two sets of requirements. The requirements that go into effect in January apply to on-premises, fixed-location devices. One year later, in January 2022, devices that are off premises and don’t have fixed locations will be covered under the regulation, as well.
Given the rise of remote working due to the pandemic, this latter set of requirements will affect most businesses.
What are the new requirements?
You can find detailed information here, but below is a high-level overview.
Kari’s Law now requires multiline telephone systems (MLTS) manufactured or installed after Feb. 16 to:
  • Enable users to dial 911 directly, without having to enter a prefix such as “9” to reach an outside line
  • Provide for notification (e.g., to a front desk or security office) when a 911 call is made so long as the system can be “configured to provide such notification without an improvement to the hardware or software of the system”
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. Notification must include, at a minimum, the following information:
  • The fact that a 911 call has been made
  • A valid callback number (if feasible)
  • The information about the caller's location that the phone system conveys to the public safety answering point (PSAP), if feasible
RAY BAUM’S Act requires that:
Effective Jan. 6, 2021, for on-premises, fixed-location devices, the 911 call must convey a “dispatchable location” to 911 call centers, so that the PSAP will receive the caller’s location automatically and can dispatch responders more quickly.
Effective Jan. 6, 2022, the requirement to convey a “dispatchable location” expands to include on-premises, non-fixed and off-premises devices (where feasible). Otherwise, the system must provide either:
  • A dispatchable location based on end-user manual update
  • Alternative location information that meets these requirements:
    • It may be coordinate-based, and it must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings
    • Off-premises devices (associated with the business phone system) must provide either dispatchable location based on end-user manual update or coordinate, and that must consist of the best available location obtainable from any available technology or combination of technologies at reasonable cost
“Dispatchable location” is defined as “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.”
This is especially important in situations presented by campus environments and multistory buildings.
What else should I know?
It’s important to understand that station-specific information is NOT required at this time. Some vendors were pushing for this level of detail to be mandatory, because they have solutions that provide this information and would profit from such a requirement. However, the final law requires less specific information.
Eventually, the courts will likely define the actual information required as a “dispatchable location.”
Summing it up
You can’t ignore this stuff. It’s complicated and will require consideration, and possibly process changes or additional tools. You must understand the two choices for providing location information, and their implications. You may want to consider hiring a consultant to help you work through this.

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"SCTC Perspective" is written by members of the Society of Communications Technology Consultants, an international organization of independent information and communications technology professionals serving clients in all business sectors and government worldwide.