Enterprise E911: New Laws Require Careful Consideration by Communication Service Providers (CSPs)

Posted on March 30, 2020

Emergency communications have seen drastic improvements since the first 911 call was placed back in 1968. However, some features of current enterprise communications technologies put users of the service at risk when it comes to securing 911 support. Multi-line telephone systems (MLTS), which are deployed in the majority of offices, hotels, and educational and healthcare institutions nationwide, can cross many public safety jurisdictions, creating problems during emergencies when accurate caller location information and callback capabilities are not made available to public safety entities.

But new laws are now in effect to address these challenges, and businesses and communications service providers (CSPs) need to take note in order to ensure compliance.

Key Challenges for E911 and MLTS

State-Specific Regulations

There is no consistent, federally mandated 911 standard for MLTS, and laws for each state can be complicated and varied, creating a patchwork of disparate requirements across the country. If you have just one employee or user in a state, you must comply with that state’s requirements. It’s important to examine the 911 policies in those states. In some cases, the penalties for non-compliance are severe, including prison time.

Increased Enterprise 911 Call Volume

Many states that provide statistics on 911 call volume report a year-over-year rise in the number of 911 calls from MLTS. First responders and security teams across the country have stepped up their training to manage emergencies, such as active shooter scenarios, that may occur in an enterprise or school environment. From a technology perspective, the new federal regulations will help organizations improve how they support their users, students, guests and employees in the event of an emergency on their premises.

New Regulations for E911

Kari’s Law and RAY BAUM’S Act

Kari’s law, which amends the Communications Act of 1934, is named in honor of Kari Hunt Dunn, whose tragic passing in 2013 alerted the nation to the dangers of requiring a dialing prefix to access 911. Her 9-year-old daughter was with her at the time of the incident and was unable to reach emergency services because she didn’t know she had to dial “9” to reach an outside line before calling 911 from the hotel where they were staying. Thanks to the tireless advocacy of 911 champions, like Hank Hunt, Kari’s father, Americans across the land will benefit from easier access to 911 when connecting to the service from certain private phone systems. RAY BAUM’S Act also addresses the need for improvements to communication systems to ensure that responders can easily locate the emergency.

These new federal regulatory obligations mean that any person or enterprises may not operate, manufacture, import, sell, or lease multi-line telephone systems in the U.S., unless the required changes are implemented. The changes include:

  • Direct Dial for 911. Kari’s law requires that enterprises operating MLTS systems provide direct access to 911 without dialing any prefix, post-fix or trunk access code. This ensures that users of the phone system, who may not be familiar with its operation or thinking clearly in an emergency, can access emergency services quickly. As of February 16, 2020, manufacturers, sellers, and lessors may NOT manufacture, import, offer for first sale or first lease an MLTS, unless it is pre-configured to allow direct dial to 911. Similarly, installers, managers and operators may NOT install, manage or operate an MLTS, unless it is configured with direct dial for 911.
  • Location Notification Capability. Whenever 911 is dialed within the enterprise, Kari’s law requires that notification must be sent to a central location at the facility where the system is installed, or to another person or organization outside the location where it is likely to be seen. The notification must include: The fact that a 911 call was made; a valid callback number; and, with limited exceptions, the same location and callback information that is conveyed to the public safety answering point (“PSAP”) with the call to 911. The notification helps ensure that the organization from which the call is made is aware there is an emergency in the building and can help facilitate the emergency response, such as providing entry into areas requiring a card key. As of February 16, 2020, installers, operators and managers of MLTS systems must ensure that equipment installed, managed or operated, is configured with this capability, unless it would require an improvement to the system hardware or software.
  • Precise Dispatchable Location. Section 506 of RAY BAUM’S Act requires that with every 911 call, precise location information is provided to enable emergency responders to more easily locate the emergency. Previously, location information might be generic, such as a street address or administrative office for a large office complex, rather than the actual location from where the call originated. The new law ensures that emergency personnel know exactly where they need to go – such as the floor, suite number, conference room or other precise location information. The new rule applies across platforms and technologies, including MLTS and VoIP.
  • Deadlines for Compliance – Because the technical ability to provide Dispatchable Location information, and the manner of compliance will differ by technology, the FCC adopted deadlines of one-year (for fixed systems) and two-years (for non-fixed systems) from the rules’ effective date, to allow for implementation. Specific details on the rules and compliance timeline by technology can be found here.

Immunity from Liability

In addition to wanting to do the right thing to ensure the safety of users of their phone system, enterprises may be concerned about the legal and financial risks when a 911 call is made from their premises or over their MLTS. The FCC confirmed that manufacturers, importers, sellers, lessors, resellers, operators and managers of MLTS have the same immunity from liability that the FCC previously granted to wireless carriers and other emergency communications service providers in connection with their transmission of emergency communications.

This immunity is intended to be at least as broad as the protections that are afforded to local exchange telephone companies under federal or state law. Enterprises need to understand the scope of this immunity for their business, which requires consideration of individual factors, including the geographic location of the MLTS facilities and the callers using the system.

Next Generation 911

Though there are no regulations around adopting Next Generation 911 (NG911) capabilities at this point, it’s important for companies to understand where the technology is headed and determine when is the right time to put the infrastructure in place to support these advanced capabilities. NG911 includes routing all emergency calls entirely over IP and enabling the transmission of photos, video and text messaging, among other things. Though only a small number of the nation’s public-safety answering points (PSAPs) are VoIP-enabled today, this will become more widespread and NG911 is likely to become regulation in the future.

While the E911 regulations create work for enterprises and communication service providers, it’s important to ensure compliance with the law and the safety of the users of the MLTS who have the expectation of a swift response when dialing 911.

Working with a knowledgeable partner, like Flowroute, can help streamline and expedite the process of making the needed changes. And in the end, it’s encouraging to know that technology continues to improve for the good of all, and that laws are enacted to ensure the new technology is used consistently so we are all safer as a result.

For more information about E911 regulations and changes, check out the following Flowroute blog posts:

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