This blog was created to help you understand and comply with the laws and rules related to Kari’s Law and RAY BAUM’S Act. Information in this blog is taken from Federal Communications Commission (FCC) resources and 911.gov; only minor modification in text for readability, understanding, and organization has been made. References to FCC documents are included at the bottom of this post for more information.
Who is affected by Kari’s Law & Ray Baum Act?
These impact service providers, system manufacturers, state and local 911 authorities, emergency communications centers (ECCs)/public safety answering points (PSAPs), and owners/operators of multi-line telephone systems (MLTSs). Both laws, as implemented by the FCC, impact any company providing MLTS service and enterprises of any size using an MLTS, such as:
- Companies with offices in multiple locations
- Campuses – including K-12, universities, and colleges
- Retail facilities
- Financial institutions
MLTSs serve millions of employees, residents, and guests of businesses and educational facilities, including corporate business parks, hotels, college campuses, and planned community developments. These systems can support anywhere from ten to thousands of individuals (stations) or telephone numbers.
MLTSs include a widely embedded base of legacy private branch exchange (PBX), central office exchange service (Centrex), and key telephone systems (KTSs); Internet Protocol (IP)-based systems; and hybrid systems. Emergency calls from MLTS stations generally only provide a PSAP with a telephone or circuit number of the system’s outgoing trunk, and not the emergency caller’s individual location. In some cases, the MLTS station that placed the call will not have its own telephone number. As a result, PSAPs often find they are unable to locate the caller using the MLTS station from which the call originated. (FCC PS Docket No. 18-261, Report and Order, pg. 3.) The FCC’s rules ensure that when a 911 call is placed on an MLTS, the system must be configured so that a notification is sent to a central location (e.g., front desk or security office) where someone is likely to see or hear it. The notification is intended to help signal someone that an emergency response is coming so that they may prepare for responders by checking on the victim, opening a gate, or unlocking a door, etc.
Amends the original Telecommunications Act of 1934 as well as its 1996 overhaul. The law and FCC rules to enact both Kari’s Law and the RAY BAUM’S Act mandate that Enhanced 911 (E911) accessibility and notification be part of every aspect of a telephone system.
Kari’s Law ensures that every person can easily call for help and be more easily located by emergency services. Kari’s Law was created after Kari Hunt was stabbed 21 times by her estranged husband on December 1, 2013, in a Texas motel bathroom while her three children were on the other side of the door. Her daughter tried four times unsuccessfully to dial 911, unaware that the hotel telephone system required dialing an additional access digit, “9,” to reach an outside line.
After public outcries over Hunt’s death, and the tireless efforts of Hunt’s father, Congress took action and enacted Kari’s Law in 2018. Soon after, the FCC began its notice of the proposed rulemaking process. Manufacturers and vendors of MLTSs must pre-configure systems to support direct dialing of 911 without having to dial any prefix or access code. MLTS installers, managers, and operators not only must ensure that the system supports 911 direct dialing, but must also convey notification that a 911 call has been made.
When a 911 call is placed on an MLTS, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Examples of notifications include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. The notification shall include, at a minimum, the following information:
- The fact that a 911 call has been made
- A valid callback number
- The information about the caller’s location that the MLTS conveys to the PSAP with the caller to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information. (47 CFR § 9.3.)
RAY BAUM’S ACT
Applies to the following 911-capable services: MLTS, fixed telephony, interconnected Voice over Internet Protocol (VoIP), internet-based Telecommunications Relay Services (TRS), and mobile text.
Named in honor of Ray Baum, the 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 particularly focused on 911 emergency services for enterprises. The FCC recently adopted regulations aimed at ensuring that the advanced communications tools used in an enterprise environment continue to support critical end users’ 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.
Section 506 of the RAY BAUM’S Act requires that the FCC consider adopting rules to ensure “dispatchable location” information is conveyed with 911 calls, regardless of the technology used, so that PSAPs will receive the caller’s location automatically and can dispatch responders quickly and accurately locate the caller. Dispatchable location information includes the street address of the caller and additional information, such as a room or floor number, or similar information necessary to adequately identify the location of the calling party as quickly as possible.
NEED MORE INFORMATION?
911 Requirements for MLTS – 47 C.F.R. Part 9, Subpart F
Frequently Asked Questions – MLTS FAQs
Small Entity Compliance Guide: https://www.fcc.gov/document/implementing-karis-law-and-section-506-ray-baums-act-0
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