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Build a strategy for compliance with federal 911 laws

Federal 911 laws are now fully in effect. Learn what your organization's obligations are to ensure PBX and phone system compliance with Kari's Law and RAY BAUM's Act.

With federal regulations around 911 calling and location information fully in effect and enforceable, organizations need to ensure their PBX and phone systems are compliant.

"There are obligations for everyone, from the manufacturer and distributor through to the operator of any multiline telephone system," said Martha Buyer, a telecommunications attorney.

Kari's Law requires that multiline telephone systems sold, leased or installed after Feb. 16, 2020, support phones directly calling 911 without needing to dial a prefix first. The law also requires that 911 calls have a valid callback number and that appropriate on-site personnel, like security, are notified when a 911 call is made.

RAY BAUM'S Act requires 911 calls provide a dispatchable location to a public safety answering point (PSAP), which includes a street address and additional information, such as a suite or apartment number.

Buyer and other industry insiders spoke at Enterprise Connect on how to build a strategy to ensure compliance with federal 911 laws.

The business obligations for 911 compliance

If a PBX is capable of being compliant with Kari's Law and RAY BAUM's Act, then it needs to be compliant, said Mark Fletcher, vice president of public safety solutions at 911inform. In only a few cases, a PBX would not need to comply with the federal 911 laws.

There are obligations for everyone, from the manufacturer and distributor through to the operator of any multiline telephone system.
Martha BuyerTelecommunications attorney

While device manufacturers, distributors and resellers are required to offer services to comply with 911 regulations, it's ultimately up to the organization to implement and maintain compliance, he said.

Violations of these federal regulations can cost organizations $10,000 per day, Buyer said.

In addition to addressing the technical aspect of compliance, it's important for organizations to regularly meet with emergency responders to establish the information that would be most useful to them, she said. Location information that might make sense to an HR or IT team, such as cubicle designations, may not be as helpful for emergency responders.

Many organizations also run a wired PBX alongside cloud-based telephony systems, said Joshua Burch, director of product at Intrado. But, from an overall safety and employee perspective, it's better to standardize operations to have consistency for the entire workforce in terms of 911 regulatory compliance.

"Why take the chance?" he said.

Organizations also need to be aware of how new technology could affect compliance with Kari's Law and RAY BAUM's Act. For example, one trend Burch said he was starting to see was enterprises deploying their own private wireless networks to replace a Wi-Fi network. In that scenario, the enterprise is providing the network, which could mean compliance requirements for 911 location information.

"That's going to be an evolving discussion point that we're going to have more frequently," he said.

Remote work challenges for federal 911 laws

The increase in remote work during the COVID-19 pandemic added a new wrinkle for addressing federal 911 regulations. As of January 2022, under RAY BAUM's Act, wireless and off-premises devices must include dispatchable location information.

When the COVID-19 pandemic first forced businesses to shutter their offices, many employees took their desk phones home with them. Now, organizations need to ensure that enterprise desk phones in their employees' homes redirect to the PSAP.

"I live a couple counties away from the office. If I dialed a phone that's configured for the office, it would've gone to the wrong 911 center," said Robin Erkkila, 911 sales engineer for Bandwidth.

Compliance with the law requires a "reasonable effort," Buyer said. This includes educating employees, contractors and office guests on what the process for 911 compliance is. For example, organizations could issue a waiver to employees that explains, if they take a device home, dialing 911 may not provide accurate location information.

The increased use of conferencing capabilities has further muddied the waters, as employees can also use collaboration tools in place of telephony. However, organizations only need to focus on collaboration software that uses devices that connect to the public switched telephone network.

"If you can make [an outside] call on it, you need to be compliant on that device," Fletcher said.

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