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What You Need to Know About E911 Compliance and Validation

“911” is not only a vital part of our nation’s emergency response and disaster infrastructure. It’s part of our national identity. It’s the first phone number many Americans learn as a child, and it is literally and figuratively the lifeline we count on if the worst occurs. 

However, many people do not know that businesses and organizations have a part to play in the performance and buildout of America’s 911 system. The Wireless Communications and Public Safety Act of 1999 (or “911 Act”) codified “the deployment of a nationwide, seamless communications infrastructure for emergency services.”1 In the years that have followed, interrelated laws have passed, and communications technologies have evolved.

Today, it is essential for any organization that operates a multi-line telephone system of virtually any type to be E911 compliant for public safety and its legal protection. Read on to learn why and how to get started on the path to compliance and validation.

What Is E911?

E911 stands for “Enhanced 911.” Before the 911 Act of 1999, callers who dialed 911 would be connected to their local Public Safety Answering Point (PSAP). Then, they would have to supply their location for first responders to find them. E911 removes this last barrier by automatically providing the caller’s location on an Enhanced 911 system at the PSAP. First responders could then use ALI (Automatic Location Identifier) to reach those in need more quickly.

This undoubtedly saved countless lives, but with the evolution of telephony and the proliferation of cellular phones and smart devices, updates to E911 continued to be needed.

What Is NG911?

NG911 stands for “Next Generation 911.” This system allows wireless, cloud-based communications technologies to integrate with the nation’s 911 infrastructure seamlessly. NG911 enabled the system to use GIS information and smart device location data, including GPS, WIFI, and Bluetooth. Over time, the 911 system has incorporated multimedia information as well. This has enabled people to reach 911 in real-time through text, photo, and video messages.

What Is Kari’s Law?

Passed in 2019, Keri’s Law requires that every MLTS can dial 911 directly without an extension. The law was inspired by and named after Kari Hunt Dunn, who was tragically murdered in a hotel. Despite attempting to dial 911 four times, her call was never received because the hotel’s MLTS required dialing “9” before 911. While direct dialing is the most well-known component of Kari’s Law, it also contains two other important obligations: contemporaneous on-site notification and a valid call-back number.2

Due in large part to the improper configuration of their MLTS, OM Lodging, LLC was forced to pay a $42 million settlement for its part in Kari’s death.

What Is RAY BAUM’S Act?

Standing for “Repack Airwaves Yielding Better Access for Users of Modern Services” and named after the late lawmaker Ray Baum (who championed the act), section 506 applies to E911 compliance. This section emphasizes that dispatchable location information must be provided to the PSAP regardless of the technology the caller uses.

Dispatchable information includes the caller’s street address as well as any other information that would be useful for first responders to find the caller, including the floor number, suite, or apartment.3

Who and What Do the Rules Apply To?4

Kari’s Law and RAY BAUM’S ACT went into effect on February 16, 2020, and include but are not necessarily limited to:

 

  • Companies with offices in multiple locations (including hybrid and remote environments)  
  • Campuses – including K-12, universities, and colleges 
  • Hospitals 
  • Hotels 
  • Retail facilities 
  • Financial institutions
  • MLTS [start second column here]
  • Fixed telephony 
  • Interconnected VoIP 
  • Internet-based 
  • TRS Mobile text

What Could This Mean for You?

While we can’t give any specifics without learning about your unique business, operations, and telecommunications, it could apply to countless organizations and communications platforms. And Kari’s Law doesn’t only apply to the device manufacturers, distributors, and installers—it applies to everyone in the communications technology chain—including the end user.5

The good news is that Keri’s Law and FCC rules are “forward-looking,” meaning they do not apply to “any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020.”6

The bad news is that in being “forward-looking,” it will apply to emerging and future technologies, such as applications that can be “delivered dynamically via web and HTML interfaces.”7 For now, that means many of the communications technologies that remote and hybrid employees rely on. In the future, it could apply to a range of technologies that your organization may wish to employ.

Compliance and Validation

Unfortunately, achieving compliance isn’t as straightforward as it may seem. For example, the government states that “any MLTS manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020” will not be subject to Kari’s Law. 

But according to an attorney involved in the creation of Kari’s Law, Martha Buyer, “Enterprises that operate multi-line telephone systems, and have either installed new systems or completed a major upgrade since February of 2018, don’t really have an excuse for non-compliance that would likely hold up in court. There are other areas of state and federal laws that, if not specifically requiring compliance, suggest that non-compliance is a bad place to be. Specifically, OSHA regulations require organizations to provide a safe workplace. It would not be a tough argument to make in court that anything that could be construed as denial to access of 911 absolutely creates an unsafe workplace.”8

As achieving compliance is potentially complex, so too is validation of compliance, which involves coordination with your local PSAP and first responders. This 39-page PDF from 911.gov is a great place to start on both endeavors.

1 https://www.fcc.gov/general/9-1-1-and-e9-1-1-services
2 https://www.nojitter.com/e-911/hybrid-workforce-technology-not-immune-e911-regulations
3 https://www.fcc.gov/mlts-911-requirements
4 https://www.911.gov/assets/Karis_Law_And_RAY_BAUMS_Act-Oct_2020.pdf
5 https://www.nojitter.com/e-911/hybrid-workforce-technology-not-immune-e911-regulations
6 https://www.911.gov/assets/Karis_Law_And_RAY_BAUMS_Act-Oct_2020.pdf
7 https://www.nojitter.com/e-911/hybrid-workforce-technology-not-immune-e911-regulations
8 https://www.nojitter.com/e-911/why-you-must-validate-compliance-new-e911-laws

Get Help with E911 Compliance

Achieving compliance and first-time verification are processes that would warrant several separate blog posts to cover in any detail. Then, you must consider that follow-up verification should take place every year thereafter or whenever there is a significant change to your MLTS. Aside from the humanitarian obligation to make it as easy as possible for your employees, customers, or clients to be able to get the help they need, there is also a significant concern of legal liability. In short, E911 compliance is an area where organizations need a communications technology expert on their side.

With more than 42 years of communications and IT experience, IPC Tech is not only skilled with the current and legacy technologies that are affected by E911 compliance, but we’re also able to ensure that future technologies you choose to employ will be compliant and validated.