Ensuring 911 calls are routed and responded to correctly is a challenge that has grown more complex as companies embrace the cloud and usher in the hybrid workplace. One thing that hasn't changed: The key requirement that calls placed to 911 emergency call centers reach the right operator and that the operator can determine the caller's location.
Let's examine what you can do to navigate E911 in a hybrid workplace and ensure compliance.
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.
In the United States, companies are subject to both federal, as well as state and local government, regulations. At the federal level, two key laws are Kari's Law and RAY BAUM's Act.
Kari's Law, in force for multiline phone systems sold, leased or installed after Feb. 16, 2020, requires that all phones can directly dial 911 without requiring users to punch in a prefix, such as an 8 or 9, to reach an outside line. It also requires that appropriate personnel, such as on-site security, are notified whenever a 911 call is made. Additionally, it mandates 911 calls sent to an emergency call center (ECC) or a public safety answering point (PSAP) must include a valid callback number to enable the operator to reach the original caller if the call is lost.
RAY BAUM's Act mandates that calls placed to 911 provide a dispatchable location, which the Federal Communications Commission defines as a validated street address of the calling party, plus additional information, such as apartment, suite or desk location, adequate enough to identify the caller's location.
In many cases, building access is restricted so it's critical that front-desk security personnel are aware that a 911 call was placed from within the building and the caller's actual location.
Unfortunately, not all companies adhere to regulations. According to Metrigy's "Workplace Collaboration 2023-24" study of 440 companies, just 63% of organizations with offices in the United States complied with both Kari's Law and RAY BAUM's Act.
Defining compliance remains an obstacle for many companies. For newly installed platforms or deployed cloud services, compliance means alignment with Kari's Law and RAY BAUM's Act, along with applicable state and local regulations. But, for older systems, compliance can often be a gray area depending on the age of the platform and when it was last updated. To minimize risk, companies should consult with appropriate legal counsel.
Fortunately, both unified communications (UC) vendors, as well as third-party software suppliers, offer tools that provide compliance while managing employee location and 911 call routing. These range from apps that manage employee location in real time to those that ensure that location information is shared both with on-site personnel and ECC/PSAP operators. In cases where a 911 caller's location can't be pinpointed, the software typically routes the call to a national call center that attempts to determine caller location before contacting the appropriate ECC.
Some UC providers support Next Generation 911 (NG911) capabilities, where endpoints learn their location from network components or other devices and then send that information along with the 911 call. Emerging NG911 capabilities include text-to-911, where available, and the ability to share information with first responders, such as exit locations, elevators and even security camera footage. For remote workers, most services require that users configure a dispatchable location. The UC software validates the address is correct and prompts users to update their locations when it detects a change in network environment.
Mobility emerges as a pain point
The reality for companies trying to ensure E911 compliance is that most 911 calls are placed from personal or company-provided cellular phones. In these cases, because the call isn't handled by the enterprise phone system or UC as a service (UCaaS) provider, there may be no way to transmit accurate caller location or to notify on-site personnel that an emergency call has been placed. Some providers -- among them 911inform -- can link personal or company-provided cellphones to office locations, but these products aren't widely deployed. Metrigy found that only 16.1% of companies use third-party platforms for 911 call and location management.
New mobile services that interface the native dialer app on a cellphone with a company's UCaaS provider, such as Cisco Webex Go and Microsoft Teams Mobile, also lack the ability to transmit detailed user location information or notify on-site personnel, potentially creating new liability concerns -- here again, it's best to consult legal counsel to determine risk.
Education, tools can help
To help reduce 911 compliance challenges and make it possible to navigate E911 in a hybrid workplace, consider the following steps to minimize risk:
- Ensure compliance with appropriate federal, state and local laws.
- Deploy available 911 management tools from your UC providers, supplementing with third-party specialty tools as needed.
- Determine and address risk of mobile 911 calls.
- Educate users about how 911 calls are handled across all work locations.