With all of the distractions in 2021, many people aren’t aware of a new federal requirement that governs 911 calls and the phone systems that originate these calls. These new laws particularly impact the vast number of organizations that migrated to cloud telephone providers to support remote workers during COVID-19.
In August 2019, the Federal Communications Commission (FCC) adopted rules
to strengthen emergency calls. The newest requirement is the second part of RAY BAUM’S Act
, which applies to multi-line telephone systems (MLTS). That means the laws apply to every business with two or more phone lines as part of their phone system.
Last year, requirements to convey a dispatchable location to the 911 call centers took effect for devices located at fixed positions on the business premises. Its purpose is to ensure that the public safety answering point (PSAP) automatically receives the caller's location and can dispatch responders faster—which is critical for campus environments and multi-story buildings.
Effective Jan. 6, 2022, the requirement expands to include on-premises, non-fixed and off-premises devices (where feasible). This phase marks the first time that 911 calling requirements apply to remote and mobile workers. This requirement impacts many organizations, and you must consider numerous factors when implementing a solution. There are technical choices in how to provide location information and their implications must be understood. Remote users could be required to manually input address information, and this may require updates in employee policies.
Many details, acronyms, and definitions come into play, but the bottom line is that RAY BAUM’s Act
can impact your business.
The rule applies to systems installed after Feb. 16, 2020. Technically, it may not apply to your situation.
However, don’t relax until you look beyond the technicalities to the bigger picture. Remember, this law could still affect your organization.
When speaking to Martha Buyer
, a telecommunications attorney, 911 expert, and fellow No Jitter contributor, Buyer said, “employers have an absolute obligation to provide a safe workplace.”
To elaborate, Buyer explained how it doesn't “take a great lawyer to make a strong argument that a lack of access to accurate and reliable 911 information leads to an unsafe workplace.” Such a lack of information places “significant liability on employers that have chosen not to take the reasonable steps necessary (here, “reasonable” is a legal term of art) to ensure a safe workplace,” Buyer added.
Organizations must provide similar treatment to employees in different locations, Buyer noted. Some states have specific requirements for the level of location detail required for 911 calls. If an employer complies with the more demanding 911 requirements in one state, they must take the steps necessary to provide sufficient and similar detailed information in all states where employees are present, regardless of those state requirements.
You must recognize that implementing a solution goes beyond technical requirements (although there are many technical details to consider). Even so, decisions about managing 911 location information should expand beyond the IT and Communications departments to include representatives from areas such as Risk Management, Legal, Finance , HR, and Facilities (or other departments that will bring valuable and useful ideas to the table). Additional points of view make it more likely the outcome will reflect the input of those who may be most critically affected.
Summing It Up
You can’t ignore this stuff. It’s complicated and will require thought, technical expertise, 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.
Melissa 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.