Earlier this year, the President signed into federal law the Kari’s Law Act of 2017, a measure aimed at ensuring multi-line telephone systems (MLTS) users can directly access emergency personnel by dialing 911 without first dialing an access code. As you’ve probably observed, the passage of this new federal law was somewhat bittersweet, as the efforts to pass the law stemmed from a tragic event in 2013 where the inability to directly dial 911 from a hotel room resulted in a potentially preventable homicide. You’ve also probably observed that it took over four years for the federal government to adopt basic, uncontroversial, and seemingly common-sense requirements for how 911 calls from MLTS should work. Putting all that aside, Kari’s Law is now the law of the land when it comes to direct access to 911 from MLTS. But that’s not the end of it.
While progress in this area seems slow, lawmakers (and the industry as a whole) have been attempting to tackle, in addition to Kari’s Law, other MLTS/911-related issues that have been percolating for a while. This means more changes may be on the horizon, including some that might eventually result from a proceeding at the FCC involving 911 and Enterprise Communications Systems (ECS), a new term the FCC used to include both legacy MLTS and more advanced systems such as those using Internet Protocol or cloud-based services. For the companies that are involved with MLTS or ECS and 911, it’s a good time to take note of the landscape to implement necessary changes and to be prepared for other requirements that might be coming down the pipe.
Since Kari’s Law has been at the forefront of the discussion in the past few years, we’ll start there before circling back to other developments, including those at the state-level and at the FCC.
As you probably know, many telephone systems (in offices and hotels, for example) require an access code, or dialing prefix, to initiate calls outside of its system. This practice has proved problematic for users attempting to dial 911 who may be unfamiliar with the telephone system (e.g., children who have never worked in an office environment or made calls from hotels). Kari’s Law responded to this problem by mandating a new technical capability for MLTS, which is defined as “a system comprised of common control units, telephone sets, control hardware and software and adjunct systems.” Network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone System, are included within this definition (which makes it more or less equivalent to the FCC’s ECS nomenclature, which is intended to refer to “the full range of networked communications systems that serve enterprises” – so we may use MLTS and ECS interchangeably).
Specifically, Kari’s Law, effective as of February 16, 2018, mandates that MLTS are preconfigured such that a user may dial 911 without first dialing any additional digit, code, prefix, or post-fix, even if the MLTS otherwise requires it for other calls outside its system. This means that nobody, including telephone companies selling MLTS services, may install, manage, or operate MLTS that lack that capability. To tackle the issue from another angle, Kari’s Law also prohibits the manufacture, importation, sale, and lease of MLTS without this capability, but that requirement has a two-year grace period and won’t take effect until February 16, 2020. Lastly, whenever 911 is dialed from an MLTS, the system must be configured to provide a notification to a central location at the facility where the MLTS is installed, or to a different location of the system operator’s choosing. These notifications are intended to alert the person or organization responsible for security that a potential emergency exists. This requirement does not have a grace period, taking effect immediately. However, it will only apply if the system can be so configured without an improvement to the hardware or software of the system.
While Kari’s Law just took effect in 2018, that doesn’t mean it’s been a lawless MLTS/911 landscape or that the issues haven’t been deliberated at many levels. Continue Reading