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Posted on December 20, 2017 by West Corporation 


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Enterprise E911 Regulations Explained

Mary Boyd
VP of Government & Regulatory Affairs

Emergency communications have improved exponentially since the first 911 call nearly 50 years ago. However, some features of our present day enterprise communications technology has placed users of this service at a disadvantage when it comes to 911. The flexible nature of multi-line telephone systems (MLTS) can cross many public safety jurisdictional boundaries. This creates problems during emergency situations calls when valuable accurate caller location information and call back capabilities are not made available to public safety entities.

In my work with the FCC and other federal and state agencies, I see public safety policy discussions and proposed regulations focused on areas that will improve the security, reliability and availability of Enhanced 911 (E911). In this blog, we’ll look at how this activity will likely affect organizations with MLTS.

4 KEY CHALLENGES OF e911 & MLTS

I’m passionate about the issues of 911 within MLTS for good reason: wireless, wireline and VoIP communications are all subject to federal regulations. MLTS, meanwhile, deployed in the majority of offices, hotels and educational and healthcare institutions nationwide, are the only communications service that does not have a nationwide regulatory policy for 911.

There are several issues that organizations with MLTS should monitor and address:

1. State-Specific Regulations

Because there is no consistent, federally mandated 911 standard, many states have crafted their own regulations. 23 states to-date have passed E911 legislation, with New York, New Jersey and Nebraska now considering new mandates. The MLTS laws for each state can be complicated and varied, creating a patchwork of disparate requirements across the country.

Existing E911 Legislation

 states with e911 MLTS regulations

The regulatory reality is that if you have just one employee or user in any of the states highlighted in blue above, you must comply with that state’s requirements. In some states, buildings with more than 7,000 square feet must provide floor and the specific location of the communications device—including floor details—along with the street address. In other states, any building less than 40,000 square feet in size need only provide the street address.

If your company provides enterprise services and your employees work from remote locations, take the time to examine the 911 policies in those states. In some cases, the resulting penalties for non-compliance may surprise you. Kentucky, for instance, has enforcement action that can include up to 90 days in prison.

2. Caller Location

In many jurisdictions, 911 calls are dispatched with an expectation of a five-minute response time. Imagine a large hotel or sprawling office complex with several multi-story buildings and 100 rooms or offices on each floor. Armed with nothing more than a street address, there’s very little chance that first responders can reach victims within a five-minute window.

office park with MLTS

Enterprises also have a responsibility to consider the circumstances and mindsets of users during emergencies that may prompt a 911 call. If a person is distressed, disoriented or afraid, it’s difficult to respond coherently to questions from a 911 call taker. For example, if he’s having a heart attack, he may not be able to catch his breath, let alone describe his precise location.

If you can more precisely identify the location of 911 callers and even simultaneously alert key contacts or security teams within the organization, you’re at a distinct advantage when it comes to safeguarding your users and protecting your enterprise from lawsuits and litigation.

3. E911 Call Routing & Location Data Accuracy

If your enterprise is distributed across multiple locations with a centralized PBX, you have a unique challenge. You’ll require a solution to help you establish local 911 call routing for those remote locations so that an employee who calls 911 from Washington, for example, isn’t routed to a public safety answering point (PSAP) in Colorado, where your company’s PBX is located.

In addition, keeping up with employee workstation adds, moves and changes within an enterprise is an administrative, time-consuming challenge for most organizations.

4. Increase in Enterprise 911 Call Volume

Many states who provide statistics on 911 call volume report a year-over-year rise in the number of 911 calls from MLTS. In California, from 2015 to 2016, the number of 911 calls jumped by almost 20%. Florida reported an almost 33% increase for the same period.

First responders and security teams across the country have stepped up their training to manage emergencies such as active shooter scenarios that may occur in an enterprise. From a technology perspective, we can prepare, as well. The need for emergency communications will never go away, but we can improve how we support our users, students, guests and employees. We can ensure that we’re enabling call routing to the correct (local) PSAP, and we can provide public safety with a call back number and a granular location for 911 callers.

Kari’s Law

Unfortunately, as often happens, sometimes it takes a tragedy to bring about awareness and change. In 2013, Kari Hunt was staying with her daughters in a Marshall, Texas hotel room when her estranged husband broke in and assaulted her with a knife. One of the daughters, as she was taught to do, picked up the phone and dialed 911. Unfortunately, she didn’t know the hotel’s MLTS required that she dial a “9” first to get an access line so she was unable to reach a 911 operator and save her mother’s life.

Kari’s resulting death inspired her father, Hank Hunt, to begin a petition campaign to require businesses to provide direct access when dialing 911 (no prefix required). Lawmakers in Washington took notice, and bills were introduced in the House (H.R.582) and Senate (S.123). Both passed with bi-partisan support. As I write this, the conference committee is working to reconcile the differences in language between the two bills. Once approved by Congress, a federal bill will be presented to President Trump for signature.

The Next Step for MLTS Legislation

In addition to the requirement of direct dial access to 911, Kari’s Law will require that businesses provide a call back number to PSAPs and enable a notification feature that alerts security teams, a front desk, etc. that a 911 call has been made from the facility.

Kari’s Law Passes House and Senate

West worked to persuade lawmakers to add an amendment to Kari’s Law requiring that more detailed location information be made available to PSAPs but, ultimately, it did not make it into the final bill. I’m still hopeful that we can accomplish the addition of a location feature at some point in the near future. After all, location of the caller is an essential requirement for public safety and first responders, and the first question most PSAPs ask is “911. Where’s your emergency?”

While Kari’s Law goes a long way towards enhancing emergency response, its passing does not mean that individual states shouldn’t continue to pursue legislation that includes requirements for a call back number and precise location information. I’m encouraged to see many states using the language of Kari’s Law to draft their own legislation. I also applaud our nation’s lawmakers for leaving the door open for states to refine their legislation on behalf of their citizens.

FCC NOTICE OF INQUIRY

The FCC’s Chairman, Ajit Pai, is extremely passionate about MLTS and enterprise solutions. On his own accord, he reached out to all the major hotel chains to encourage them to update their systems to provide unrestricted access to 911.

The FCC has previously examined the issues caused by MLTS systems, but never enacted specific regulations. Just recently, however, they issued a notice of inquiry in which Pai and FCC committee members sought information about enterprise communications systems from public safety, industry organizations and service providers. This inquiry includes a request for information on 911 call volumes and E911 and NG911 technical capabilities, as well as potential costs, benefits, best practices, recommendations and more.

FCC Notice of Inquiry

This activity signals to me that the FCC is seriously considering the 911 issues associated with enterprise systems, and West is supplying information regarding this inquiry. If you’re interested in monitoring the comments filed by the industry, you can search for Docket 17-239 on the FCC’s website.

FINAL THOUGHTS

It’s estimated that we spend anywhere from 25 to 30% of our time at work, most of us from offices or facilities with MLTS. During that time, your enterprise users have an expectation that if they pick up the nearest phone and call 911, help will arrive quickly. In addition to complying with the E911 regulations and reducing the risk of litigation, we can help improve the odds of positive emergency outcomes by:

  1. Providing direct dial access to 911 (no prefix required)
  2. Using caller location to route the 911 call to the correct PSAP
  3. Delivering public safety with precise caller location information plus a call back number
  4. Notifying on-site contacts such as a security team or a front desk

In a future post, I’ll look at the industry and legislative activity impacting carriers and our nation’s PSAPs. In the meantime, you can watch our E911 Legislation On-Demand Webinar where my main focus is on 911 regulations in the enterprise.



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