Guide to 911 Regulations

As companies increasingly adopt innovative communications platform capabilities in the workplace, it has become increasingly imperative that their 911 calling capabilities keep pace as well. As a result, the FCC has recently adopted new regulations aimed at ensuring that the advanced communications tools used in an enterprise environment continue to support critical end-user’s emergency response needs–when and where they are necessary.

Signed into law in 2018, RAY BAUM’S Act emphasizes the importance of sharing precise location information when calling 911, which is invaluable to first responders in locating callers and can dramatically increase the potential for better emergency outcomes. 

What is RAY BAUM’s Act?

Named in honor of Ray Baum (more on him below), RAY BAUM’s Act is also an acronym that stands for Repack Airwaves Yielding Better Access for Users of Modern Services.  While the Act in its entirety includes many different communications related initiatives, Section 506 of the Act is what Leaco is particularly focused on with its 911 emergency services for businesses. 

Who was Ray Baum? 

Ray Baum described himself as “just a small-town lawyer” but he went on to serve in a number of important public roles at the state and federal level in Oregon and in Washington D.C. over the course of his career. Ray was a Commissioner and Chairman of the Oregon Public Utilities Commission (PUC), served on the Board of Directors of the National Association of Regulatory Utility Commissioners (NARUC), and as the Chair of NARUC’s Committee on Telecommunications. 

Ray Baum joined U.S. Representative Greg Walden’s staff as Staff Director on the Energy and Commerce Committee in December 2016. In this role in Congress, Ray worked closely with the FCC on telecommunications issues. Sadly, Ray Baum passed away in February of 2018 after a long battle with cancer. In recognition of his important contributions to the telecommunications industry, Representative Greg Walden arranged to have RAY BAUM’S Act named in his honor. 

SECTION 506 OF RAY BAUM’S ACT

The language of Section 506 of RAY BAUM’S Act directed the FCC to conclude a proceeding aimed at improving the “dispatchable location” information provided to public safety at the time of a 911 call. In the FCC’s proceeding that followed, it determined that dispatchable location includes a street address, but should also include more granular information such as building number, floor, suite, room, or other available relevant location information that can best assist first responders in an emergency. 

When does RAY BAUM’S Act go into effect?

The FCC’s new rules were published in the December 6, 2019 Federal Register. In accordance with the FCC’s order implementing RAY BAUM’S Act, the initial compliance dates for the Section 506 “dispatchable location” components of RAY BAUM’S Act are:

COMPLIANCE DATE

Fixed Multi-line Telephone Systems (MLTS)
 Fixed Interconnected VoIP
 Fixed telephony
 Fixed Telephone Relay Services (TRS)

January 6, 2021

Non-fixed Multi-line Telephone Systems (MLTS)
 Non-fixed Interconnected VoIP
 Non-fixed Telephone Relay Services (TRS)

January 6, 2022

What does RAY BAUM’S Act mean for your business?

o First, we strongly urge impacted companies to speak with legal counsel for guidance. The best legal approach for any given business may vary depending upon the nature of the services in question or the size and complexity of your company. 

o Second, the provisioned emergency location information for your employees may need to be updated to include additional data such as building, floor number, suite, conference rooms, etc. to provide more granular location information. All provisioned emergency location information should be validated to ensure consistency with public safety address standards. 

o Third, you will need to plan for workers who may be using nomadic services such as softphone applications on a laptop or other mobile devices. Many companies we work with are transitioning away from traditional, fixed desktop phones. They will likely need to adjust how they manage their emergency location information to account for new nomadic communications services that commonly allow employees to work in the office and remotely. 

o Finally, endpoints need to be tested to ensure that the correct emergency location information will be conveyed to public safety during a 911 call. Such testing might ordinarily require contacting and coordinating with appropriate 911 call centers.

How is RAY BAUM’S Act related to Kari’s Law?

Both Kari’s Law and Section 506 of RAY BAUM’S Act deal with E911 and MLTS. Kari’s Law has two requirements:

1. Eliminates      requiring that a prefix or digit (such as 8 or 9) be dialed before calling      911.
2. Designated      personnel (e.g., a security team or front desk attendant) must be notified      that a 911 call has been placed.

Kari’s Law (which goes into effect on February 16, 2020) focuses on ensuring that end-users can make calls to 911 in enterprise environments while notifying the enterprise of the emergency. Section 506 of RAY BAUM’S Act is concerned with the quality of the information that is sent to public safety operators when the call is made. Together, they are all about providing better, faster, more reliable access to emergency services when dialing 911.

Who’s Affected by Kari’s Law and RAY BAUM’s Act?

Both laws impact enterprises using multi-line telephone systems (MTLS), such as:

• Companies with offices in multiple

locations

• Campuses–including K-12, universities,

and colleges

• Hospitals

• Hotels

• Retail facilities

• Financial institutions

• Warehouses

Key Takeaways 

• Managing 911 requires full understanding of legal and regulatory risks. Potential exposures occur when enterprises: 

• Fail to adequately plan for remote workers, satellite campuses, etc. 

• Fail to provide dispatchable location information at the time of a 911 call 

• Do not alert security teams and other key personnel that a 911 call has been made 

• Intercept 911 calls before sending directly to public safety • Replace PRI or dedicated circuits and move to the cloud 

• With the passage of the two important pieces of legislation, the FCC is rapidly moving toward establishing uniform federal standards for precise “dispatchable location” as well as internal notification of on-site teams to assist in response. 

• On February 16, 2020, businesses must be compliant with Kari’s Law. 

• Applies to MLTS systems “manufactured, imported, offered for first sale or lease, first sold or leased, or installed” after the compliance date 

• Be aware that businesses that may not be legally mandated to support these requirements on February 16, 2020 may still be at risk from litigation and negative media attention if users’ expectations are not met.

Don’t go at it alone. 

Complicated regulations can seem overwhelming, but Leaco can help. Our team can help you navigate these complex requirements while also helping to ensure your employees, guests, and customers are protect