For those who manage phone systems, a key responsibility is tracking phone locations and 911 call routing.
That task has been complicated by the rise of softphones and embedded dialers, coupled with the shift to cloud-based communications. The days of simply managing desktop telephones at fixed locations are over.
In addition, new federal regulations often supersede the patchwork of state and local laws governing 911 location management. Mobile phones add another wrinkle. Their near-ubiquity raises questions about how organizations are notified when a 911 call is placed on a personal cellphone from within an office location.
An effective Enhanced 911 (E911) compliance strategy has two important pieces:
- Maintain accurate phone location information, regardless of type of endpoint and whether the endpoint is on the enterprise network or remotely connecting to company-provided phone services.
- Ensure that 911 calls are transmitted to the proper public safety answering point (PSAP) based on the 911 caller's current location. For example, if a person with a company office in Chicago is working from home in Milwaukee, the 911 call must reach the 911 operator in Milwaukee to ensure emergency personnel are dispatched to the right location.
Meeting these goals in an ever-changing environment requires a proactive approach. Improper location management and call routing makes an organization vulnerable to regulatory liability, as well as civil risk -- and, more importantly, it risks employee health and safety.
Here are five tips to ensure compliance and minimize risk.
Editor's note: This tip provides no legal guidance. We recommend those responsible for 911 location and call routing management consult with appropriate legal counsel to determine their organization's risk and potential liability.
1. Assess regulatory compliance. In the United States, two primary laws govern 911 compliance: Kari's Law and Ray Baum's Act.
- Kari's Law, with a compliance date of Feb. 16, 2020, for new multiline phone systems sold, leased or installed after that date, requires that all phones can directly dial 911 without needing to first dial a prefix, such as an 8 or 9, to reach an outside line. It also requires appropriate personnel, such as on-site security individuals, are notified whenever a 911 call is made. And it mandates 911 calls are sent to a PSAP with a valid callback number.
- Ray Baum's Act, Section 506, requires that calls sent to 911 operators provide a "dispatchable location," which the Federal Communications Commission defines as "a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party." In most cases, first responders arrive at the front door of a location and require security personnel to escort them to the caller, so it's critical those individuals know the specific location from where a 911 call originated.
In addition to these federal regulations, several states and cities have their own regulations covering segmentation of large facilities and how 911 calls are sent to local PSAPs. Addressing risk means ensuring E911 compliance for all employees, in all locations, on all endpoints.
2. Mitigate risk. IT leaders should assess what tools are available to them from their phone system providers to meet regulatory requirements and to determine what changes or additional deployments they may need to make to ensure they comply. Network-level protocols can help with tracking the location of desktop phones, but pinpointing softphones and mobile phones requires additional investment in dedicated 911 location management tools -- especially in mixed PBX or cloud calling platform environments.
Organizations should also evaluate 911 management and call routing capabilities from their Session Initiation Protocol trunking providers if they have their own public switched telephone network connectivity. Metrigy research data showed about half of companies rely on third-party or managed services to handle 911 location and call routing management. Such platforms may offer additional benefits, such as misdial prevention and 911 call recording.
3. Go beyond phones. Once a call is placed to 911 and appropriate security personnel are notified, consider how the 911 call is integrated into an emergency response plan. Vendors like Intrado, 911inform and RedSky offer the ability to integrate 911 calls into incident management platforms, enabling security personnel to not only identify a caller's location, but potentially tie that call into other available data from IoT devices, including cameras, sensors and door locks.
In some cases, the option may be available to share this information with first responders so they can assess a situation as they arrive. In addition, consider mobile phone-specific location management capabilities from vendors like 911inform.
4. Plan for Next Generation 911 (NG911). NG911 revamps location management by enabling phones themselves to determine their location via a variety of information sources, including GPS, and transmit real-time location data to the PSAP at the time of a 911 call. Advanced capabilities support new communication modalities, such as text to 911, and allow devices to share video with first responders.
5. Test, test, test. Configuring 911 location and call routing management isn't something that's done once and then forgotten. Ensure you have a regular schedule of tests across all potential calling endpoints. If available, use 933 testing to minimize calls into actual PSAPs. And, as part of your training program, ensure that employees are aware of any potential limitations in 911 call routing.
Addressing each of these E911 compliance issues creates a high likelihood that, when an employee places a 911 call, it goes to the correct PSAP and with the caller's accurate location. It also ensures a more effective response to any incidents that may have triggered the initial call.