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Calling 911 Make required changes to multiline phone systems

by: Robert C. Goldberg, general counsel for the Business Technology Association

In what can be both a requirement for your company as well as a business opportunity, new laws mandate changes to multiline telephone systems. The applicable regulations are Kari’s Law and Ray Baum’s Act.

Kari’s Law is named in memory of Kari Hunt, who was killed in 2013 by her estranged husband in a motel room in Marshall, Texas. Hunt’s nine-year-old daughter tried to call 911 for help four times from the motel room phone while her mother was being attacked, but the call never went through because she did not know that the motel’s phone system required dialing “9” for an outbound line before dialing 911. It is believed that Hunt may have survived if the call had gone through.

Congress responded by enacting Kari’s Law in 2018. Kari’s Law requires direct 911 dialing and notification capabilities in multiline telephone systems (MLTS), which are typically found in enterprises such as office buildings, hotels and on campuses. The statute required that these features take effect on Feb. 16, 2020, two years after the enactment date of Kari’s Law. In addition, Kari’s Law and the federal rules are forward-looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after Feb. 16, 2020.

Under the statute and the Federal Communications Commission’s (FCC’s) rules, MLTS manufacturers and vendors must preconfigure these systems to support direct dialing of 911 — that is, to enable the user to dial 911 without having to dial any prefix or access code, such as having to dial “9.” The system must also notify the front desk or security office when a 911 call is made. In addition, MLTS installers, managers and operators must ensure that their systems support 911 direct dialing.

By ensuring that MLTS phones no longer have to enter a prefix to dial 911, Kari’s Law will expedite emergency calls and deliver help more quickly than ever to the occupants of enterprise-level buildings. Whether they are schoolchildren, travelers, office employees or hotel workers, Kari’s Law will not only avert any confusion they might experience during an emergency, but it will also help send accurate location data along to first responders.

Under Ray Baum’s Act, the FCC has adopted rules to ensure that a “dispatchable location” is conveyed to dispatch centers with 911 calls regardless of the technological platform used, including 911 calls from MLTS. A “dispatchable location” is a location delivered to the public safety answering point with a 911 call that consists of the validated street address of the calling party plus additional information such as a suite/apartment number or similar information necessary to adequately identify the location of the calling party.

Having access to precise location data revolutionizes the approach to public safety. First responders will save time searching for callers and can instead focus their efforts on getting to the scene as quickly as possible. Considering how many lives are lost each year because first responders could not find who they were trying to help, having access to this data will undoubtedly cut that number down.

Hunt’s story is an emotional event that could have been prevented by technology changes. Please update your own system and, if you are considering adding telephone systems to your current offerings, Kari’s Law is an excellent foot in the door. n

Robert C. Goldberg is general counsel for the Business Technology Association. He can be reached at robert.goldberg@sfnr.com.