New 911 Rules (Kari’s Law and RAY BAUM’S Act) Will Take Effect Soon for Multi-Line Phone Systems
New federal regulations taking effect in February will change the requirements for how certain phone systems handle calls to 911. These laws aim to ensure that people in hotels, office buildings, dorms and other places with multi-line telephone systems (MLTS) can quickly contact emergency services in a crisis and that emergency responders have the information and access needed to reach them as soon as possible.
If your organization relies on an MLTS, here’s an overview of everything you should know about these new rules and what you can do to make sure that your business doesn’t break them.
Kari’s Law and its Requirements
In 2013, Kari Hunt Dunn was murdered by her estranged husband in a hotel room in Texas. Kari’s daughter was there during the attack and attempted to dial 911, but she couldn’t get through because she didn’t realize the hotel phone required guests to dial “9” before making external calls, according to the Federal Communications Commission (FCC).
Following Kari’s death, her father, Hank Hunt, worked with federal lawmakers to enact a law requiring MLTS to allow people to directly dial 911. Kari’s Law was officially signed in 2018, and it will apply to all MLTS imported, manufactured, first sold or leased, offered for first sale or lease, or installed on or after Feb. 16, 2020, according to the FCC.
Kari’s Law applies to any “person engaged in the business of manufacturing, importing, selling, or leasing” MLTS, as well as any “person engaged in the business of installing, managing, or operating” that type of phone system, the FCC states.
The law requires the following:
1. Allow users to dial 911 directly, without an access code or prefix such as “9” needed to connect with outside lines.
2. Send a notification to a central location (e.g., a security office or the front desk of the building) whenever someone calls 911.
In 2019, the FCC officially adopted rules to implement the direct dialing and notification regulations included in Kari’s Law. The Commission clarified that the notification should include the fact that a 911 call was made, the same location information relayed in the call to emergency services, and a valid callback number – with exceptions for the callback number and location info if including them isn’t technically feasible. Additionally, the notification must occur at the same time as the 911 call but cannot delay the call.
The Commission also specified that this law applies not only to traditional MLTS but also to Internet Protocol-based systems, including cloud phone systems.
RAY BAUM’S Act and its Requirements
RAY BAUM’S Act was also signed into law in 2018. It required the FCC to “conclude a proceeding to consider adopting rules to ensure that the dispatchable location is conveyed with a 9-1-1 call, regardless of the technological platform used,” according to the FCC.
RAY BAUM’S Act defines a dispatchable location as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.”
Simultaneously with the adoption of rules to implement Kari’s Law, the FCC also adopted dispatchable location stipulations for MLTS and services capable of dialing 911 that aren’t already subject to dispatchable location requirements, including mobile texting, interconnected VoIP services, fixed telephony, and Telecommunications Relay Services (TRS).
These location requirements apply to the same entities affected by the direct dialing and notification rules included in Kari’s Law. That means legacy MLTS (those not imported, manufactured, first sold or leased, offered for first sale or lease, or installed on or after Feb. 16, 2020) don’t have to comply.
What the New Laws Mean for Your Business
Your organization needs to adhere to these regulations if you plan on getting a new phone system on or after Feb. 16. In terms of upgrades, the FCC declined to specify in its Report and Order the level of improvements to a legacy MLTS that would necessitate compliance with Kari’s Law (and by extension, RAY BAUM’s Act) – although the Commission did express disagreement with the idea that any improvements, even small ones, should make an MLTS subject to Kari’s Law. The FCC agreed to address this issue “in response to a specific fact pattern, should one arise.”
If you’d like more detailed information about the implementation of Kari’s Law and RAY BAUM’S Act, the FCC Report and Order is available here.
Failing to comply with the new 911 rules for MLTS could result in fines and other penalties, so the Converged Communication Systems (CCS) team strongly recommends that you act to ensure compliance. Even if you have a legacy phone system that isn’t subject to these laws, you’ll have to adhere to these regulations when you get a new system.
If you’d like to update your current system to facilitate emergency response in a crisis, our engineers can review your current 911 setup. Schedule your evaluation today by calling 877-598-3999 or emailing sales@convergedsystems.com.
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