Multi-line telephone system (MLTS) owners and operators have several options for implementing Enhanced 911 (E9-1-1) and Next Generation 911 (NG9-1-1) technology. Whether the MLTS is on-prem, cloud-based, or hybrid, the organization’s responsibilities are the same. Every physical phone, softphone, call center application, videoconference application, etc., issued or in use and provided by the organization or connected to the organization’s network must be accounted for in the project plan. It is important to consider the most appropriate way to comply with FCC rules and regulations without sacrificing future options for NG9-1-1 service.
Understand the applicable legal and technical requirements. The application or phone must be able to dial 911 directly, reach the appropriate 911 center, provide a valid call back number, and simultaneously provide dispatchable location information to both the 911 Center and onsite authorities. Kari’s Law, RAY BAUMs ACT and several state mandates are enforceable today
. This requires organizations to ensure visitors, staff, patrons, students, and employees can reach emergency services by dialing 911 when they are needed.
2. Identify your stakeholders. In most cases, these will include safety and security professionals, plus representatives from legal, risk management, human resources, and facilities management. In addition, IT’s voice, network, desktop, and helpdesk support teams need to be included. Anyone responsible for end-user voice applications and the organization’s safety and security should be involved in the project planning. Stakeholders will be responsible for key decisions associated with the 911 project, including developing new policies, processes, procedures, training, and documentation across the organization.
3. Organizations with non-contiguous geographic locations should be sure to reach beyond the headquarters building or main campus and include stakeholder representation from those facilities. The requirements for branch offices may be quite different from the main office – particularly if the organization stretches across several states. In situations where there are different state laws, the best practice is to follow the most stringent requirements across all states. You should think about it this way, all employees, visitors, and patrons are entitled to equal provisions if the need to dial 911 arises.
4. Assess the current landscape. This is a key component of the project; a thorough assessment and roadmap are important for a successful outcome. During the initial stages of planning, you may want to invite a representative of the local or regional emergency response agency to speak with the project team about the current 911 system and any plans for immediate upgrades. The goal of provisioning a 911 call is to; find, route, and notify. The 911 caller’s location must be identified within the organization’s network, then be passed along through the voice service provider, handed off to the 911 network and forwarded to the 911 center. If the handoff of location information is restricted in any way, the caller may not be able to be found. It is extremely important to implement, audit and test the viability of calling 911 from various phones and voice applications from various locations. A good starting point for the assessment is to determine what works today and what does not.
5. Do your homework and be thorough when implementing the 911 solution decided upon. When you order voice circuits for your organization, only the billing number and address are typically registered as the emergency number and address associated with a potential 911 call from the organization. Depending on geographic location, this can be a huge issue. Although some organizations have utilized the voice service providers PS-ALI or VPC service in advance of legislative mandates, this is simply not enough to meet today’s or the future demands of NG9-1-1. It is required that organizations provide dispatchable location information for every 911 call on the network, regardless of the location the call is initiated from.
6. Identify and evaluate your use cases. What types of devices and voice systems currently in the enterprise would need to comply? That might include wireless handsets; soft clients for remote workers; mobile clients on employees’ smartphones, tablets, and laptops; or voice-enabled applications like Teams or Zoom. Look carefully at your current voice systems. A 911 solution will need to incorporate SIP endpoints, VoIP, TDM, analog phones, and voice applications. In the past two years working from home has become a precedent, so special care needs to be taken for remote workers. When someone plugs in a device or launches a call application from anywhere on the network, you need to be sure your 911 system can find, route, and notify the caller’s current location and share that information simultaneously with onsite personnel and the 911 Center responsible for the location of the caller.
7. Determine your internal level of involvement. Most likely, new policies, processes, and procedures will need to be developed to ensure a working solution is in place. If you have in-house security staff, you may want to add an in-house notification capability. If not, you may want to notify others responsible for emergency management in the organization. This has the advantage of alerting the appropriate people in your organization to an emergency, and it may help in coordinating with outside first-responders. This is required by Kari’s Law, and it is important to work with local first responders to assure you handle this appropriately. A basic rule is the caller dialed 911, and public safety first responders are trained professionals and responsible for handling the emergency. The importance of the internal notification is to work alongside the first responders to help with access, identifying the caller’s location and specifics associated with your organization, not necessarily to respond to the call, unless an approved policy and process for responding have been put into place.
8. Spend time on training. It is important to ensure that visitors, staff, etc., know how the technology and response to a 911 call works. For example, if the staff member is working from home, they should know how to ensure or self-report their location which can be identified if there is an emergency and 911 is dialed from a work-provided phone or application.
9. Make time for initial and ongoing testing. Testing is key to ongoing support and care of the 911 technical and policy-driven environment. Testing at the time of installation is important, as well as ongoing testing of the solution in place. Any change to the network can interfere with how this works and finding the issue in advance of someone needing emergency services is ideal. A change or upgrade to the voice platform, applications, service provider or 911 Center can cause a problem with the ability to find, route and notify of the caller’s location. It is recommended to test when changes are made as well as quarterly or bi-annually to assure 911 calling and the solution are working as designed.
10. Ongoing maintenance is as important as the original implementation and testing. The physical and technical environments can change quickly putting those dependent on the 911 system at risk. Dedicated resources should be assigned the responsibility of maintaining the data and testing the 911 solution regularly. Additional training will be needed as employees are onboarded, when a new facility is added, changes to staff and stakeholders take place, especially those responsible for safety and security. I cannot stress enough the need to engage the right stakeholders in the project in the beginning, to assure the policies, processes, and procedures put into place are tested and documented on a regular basis.
The 911 landscape is changing quickly. Transitioning from basic E9-1-1 to NG9-1-1 with more mobility of voice applications than ever before requires ongoing support and care. We recommend you engage a consultant or a subject matter expert to better understand all your options.
I am a subject matter expert, not an attorney. My opinions are based on my experience and knowledge as I am a Certified Emergency Numbering Professional (ENP) and have worked in Telecommunications with first responders for over 25 years. Vita Safety Partners
is dedicated to safety and security within the enterprise community.
Melinda is writing on behalf of the SCTC, a premier professional organization for independent consultants. SCTC consultant members are leaders in the industry, able to provide best of breed professional services in a wide array of technologies. Every consultant member commits annually to a strict Code of Ethics, ensuring they work for the client benefit only and do not receive financial compensation from vendors and service providers.