How to navigate Kari’s Law and RAY BAUM’s Act

Are you compliant with new E911 regulations?

February 16, 2020 marks the 52nd anniversary of our country’s first 911 call, but it’s also significant because it’s the day that enterprises with multi-line telephone systems (MLTS) must begin to become compliant with a new federal ruling, Kari’s Law.  

With the holidays almost upon us, 100 days is not much time to educate and prepare your enterprise, so here’s a quick primer to bring you up to speed on new expectations coming next year. 

Kari’s Law

Driven largely by the efforts of Kari Hunt Dunn’s father following the tragic death of his daughter, Kari’s Law was signed into law on February 16, 2018. Kari’s Law applies to multi-line telephone systems (MLTS) “manufactured, imported, offered for first sale or lease, first sold or leased, or installed” after the compliance date of February 16, 2020. It requires: 

• Elimination of a prefix digit such as an “8” or “9” when calling 911.
• Notification of designated personnel when a 911 call is placed. This could include a security team or front desk attendant. 

Section 506 of RAY BAUM’s Act

In addition to Kari’s Law, the FCC recently adopted additional rules for dispatchable location under Section 506 of RAY BAUM’s Act. 

According to the Report and Order, dispatchable location is defined as “the street address of the calling party, and additional information such as room number, or similar information necessary to adequately identify the location of the calling party”. “Fixed VoIP Services” will have a compliance deadline of 1 year following the formal publication of the final rules while “Non-fixed VoIP” has a two-year deadline from the publication date.

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Emergency Location from the First Responders’ Point of View

Notifications and dispatchable address are important new concepts for enterprises of all sizes to understand and implement. Imagine first responders pulling up to a large, multi-story building with hundreds of workers spread across wings and floors, some of which require badges or key cards to gain access.

Armed only with a street address, they’ll have a difficult time navigating an unfamiliar building to conduct their search. The ideal scenario is to provide first responders with precise address information (down to the building, floor and/or room number) and to designate and notify key personnel who can assist first responders as they arrive on scene, setting the stage for faster response times.  

How to prepare for E911 regulations

1. Consult with your legal teams to ensure compliance. The FCC’s August 2019 Report and Order to implement Kari’s Law and Section 506 of RAY BAUM’S Act can be found here. It’s also important to coordinate with other functions in your organization such as human resources and facilities management teams. 
2. Plan proactively for employee safety. Even if you’re not currently adopting technologies that bring your organization under Kari’s Law in February, this FCC activity suggests that these new rules will eventually affect your enterprise. Even in the absence of black and white regulations, enterprises may be exposed to risks of litigation or negative media attention if their 911 implementations are not keeping pace with the marketplace and consumer expectations. 
3. Map user endpoint locations including address, building, floor and/or room. This address should be correctly formatted and validated for errors in a master street address guide (MSAG) format. Bandwidth performs this validation and error correction as part of our easy-to-use location provisioning process (using our dashboard or APIs). 
4. Test 911 across endpoints. Bandwidth offers 933 testing, which helps to limit the disruption that occurs when scheduling and coordinating live 911 calls with public safety. Calling 933 from any Bandwidth-provisioned 911 endpoint will trigger an automated voice message relaying the caller name, call back number, and address assigned to that endpoint.