The New 911 Laws and FCC Requirements for Your Phone System

Our legal team insists, as well as common sense, that your company’s legal team review the laws for specific interpretations and how these apply to your specific business. Now that we have that out of the way we can dive into what you need to know as we head into the meat of 2020 and what is coming up in 2021.

Who Is Kari And Why Is There A Law Named After Her?

Like most laws they are reactive rather than proactive, and Kari’s Law is no different. In 2013 the daughter of Hank Hunt went to meet her estranged husband at his hotel room. He attacked and killed her in the room which is a tragedy in itself.

Kari’s nine year old daughter was in the room and tried to call 911 four times but the call would not go through. Why? Because the hotel required you dial 9 first for the call to go through. Hank went on a mission since that day to make sure this was never repeated, and good for him because we are ALL better for it. In a world that changes daily, teaching our children that 911 is a consistent you can count on is a necessity.

Kari’s Law And Your Unified Communications System

The law is fairly straightforward that if you have a multi-line phone system dialing 911 must go through without an access code. It also requires internal notification for when a 911 call is dialed. If someone dials 911 from your location on your system your security, front desk, office manager- someone needs to be notified.

Chances are, unless you are 100% wireless and only use cellular phones as a business that Kari’s law applies to you. Having a plan in place to ensure that these requirements are met is a good second step to being aware of what Kari’s Law is.

Ray Baum A Clever Acronym AND Lawyer

Ray Baum, like other legends Travis Dillard and Mike Dolloff, was born and raised in the great state of Oregon. He described himself as “just a small town lawyer”. That is just typical Oregonian humbleness of course as Ray was a Commissioner and Chairman of the Oregon Public Utilities Commission served on the Board of Directors of the National Association of Regulatory Utility Commissioners and as the Chair of NARUC’s Committee on Telecommunications.

The act itself is also an acronym meaning Repack Airwaves Yielding Better Access for Users of Modern Services. While I love the honoring of Ray and his name, accomplishments and more. We still need to define exactly what that means for your business.

In short the Ray Baum Act applies to multi-phone systems and requires additional dispatchable location information. Distilled down for us common folk, that means when you call 911 it includes floor number, suite number, room number or something beyond just the actual street address. More granular information to enable emergency services to better serve all of us, getting to where they need to be faster.

You Asked, We Answered The Pressing Questions From Our Clients

Kari’s Law and Ray Baums Act both deal with an important topic, 911 and emergency services. These are the pressing questions our clients and partners had:

Do most newer phone systems support Kari’s Law requirements?

Most newer phone systems, both on premises and cloud based DO support these requirements natively. In fact Mitel has been building the minimum requirements into systems for a long time. This has been done to avoid costly upgrades and additional purchases for the phone system.

Additionally there are some add on applications like Mitel Emergency Notification, SynApps & Informacast to name a few that make it easier to manage call alerts beyond the basic requirements.

Do most phone systems support the Ray Baum Act requirements?

Nice try trick question! Phone systems have no control over the 911 address provided to dispatchers. They do provide the 911 Caller ID that is used for address lookup by the carrier to provide information to the dispatcher.

Your requirements for the Ray Baum Act will be more around working with your carrier to make sure you are passing along a 911 Caller ID that meets the “additional dispatchable location.”

What if I have an older system that can’t comply?

Have your legal counsel read the law to see if you are exempt from having to comply with the new rules until you upgrade or replace your system.

What would you recommend for a company that has all phones send out the main phone number when placing outbound calls?

If you have a single location you can simply modify the 911 address on file for that phone number to include a building or suite number for compliance
If you have multiple locations you can differentiate normal CID and 911 CID to send a different address on calls by floor, building or location.

Does every phone need a DID to be in compliance?

Phone system-specific, but generally, no. In the Mitel system, for example, 911 CID is not dependent on having a DID on every phone. You can send out 911 CID based on Phone Switch, Site or even IP Address of device placing the call.

How does this apply to remote workers?

If someone calls 911 from a physical phone, softphone or mobile app you are required to be in compliance. If you have permanent remote workers you can register 911 addresses to the location they work from.

For roaming remote workers we recommend you train them to not use a softphone or mobile application for placing 911 calls they should use the mobile carrier network for those calls.

Cloud phone providers put this requirement on the end-users to update the address on record for 911 calls at a minimum of every 90 days.

How does corporate Bring Your Own Device (BYOD) apply in this scenario?

If an employee calls 911 using the mobile carrier network (e.g. Verizon or AT&T) those carriers will be responsible for meeting the applicable requirements.

If an employee calls 911 using a phone system mobile app then you will most likely not be in compliance unless the user’s 911 CID address is to set to the location of where the call was placed from. In this case, we recommend you train your employees to only use the cell phone default dialer so all 911 calls are placed over the carrier network.

How can you test 911 appropriately?

Do not just call 911- please! According to this from the source itself “Test calls confirm that your local 911 service can receive your 911 call and has the correct location information. Test calls can be scheduled by contacting your local 911 call center via its non-emergency phone number.

To contact the local 911 center responsible for answering calls from your location, go here and click on the state in which you are located. The person responsible for operating the state’s 911 system will be identified, and they should know who you should talk to at your local 911 call center, to schedule a day and time for test calls.”

When you put in a request to update an E911 address, how fast should the carrier take care of the update?

Carrier-dependent but typically it’s 72 hours. Your state’s public utility commission is where a complaint can be filed if you’re not ‘feeling the love.’

How do I complain about my carrier?

There is a public utility commission within each state.