New Multi-Line Telephone Systems at All Businesses Now Subject to FCC 9-1-1 Requirements

Most recently the FCC has applied 911 requirements to multiline telephone systems MLTS installed by virtually all businesses educational institutions and other establishments First adopted in 2019 the MLTS rules have gone into effect on a graduated schedule with the final rules becoming effective last year on January 6 2022MLTS include a widely embedded base of legacy private branch exchange PBX Centrex and key telephone systems as well as IPbased systems and hybrid systems MLTS serve millions of employees residents and guests at all types of businesses educational institutions hotels office parks hotels and planned community developments These systems can support anywhere from 10 to thousands of telephone numbersIn the past emergency calls from MLTS stations generally provided dispatch centers with only the telephone number or circuit number of the systems39 outgoing trunk and not the emergency caller39s individual device number In some cases the MLTS device that placed the call would not even have had its own telephone number As a result dispatch centers often found that they were unable to match an MLTS emergency call to the actual source from which it originated within a large facilityUnder the new rules existing MLTS systems are quotgrandfatheredquot and do not need to be immediately replaced or upgraded to meet the new requirements however any business that now replaces or significantly modifies its MLTS must meet the new requirements for all devices quotconnected toquot its system no matter whether they are fixed desk phones nonfixed devices such as laptops or mobile phones used on a company39s premises or nonfixed devices used offpremises that is any place that an employee may engage in remote work such as at home or at a coffee shop Companies that keep their existing systems but add devices with remote capabilities to their networks will need to make sure that not only are the new parts of their systems compliant but also evaluate whether the existing or quotlegacyquot equipment needs to be updated as wellThe specific MLTS requirements are drawn from Kari39s Law of 2017 and RAY BAUM39S Act which was passed by Congress in 2018 RAY BAUM39S is an acronym for Repack Airwaves Yielding Better Access for Users of Modern Sciences Kari39s Law is named in honor of Kari Hunt who was killed by her estranged husband in a motel room in Marshall Texas in 2013 Ms Hunt39s nineyearold daughter tried to call 911 for help four times from their motel room phone but the call never went through because she did not know that the motel39s phone system required dialing quot9quot for an outbound line before dialing 911Kari39s Law and the FCC39s implementing regulations require manufacturers and vendors of MLTS to preconfigure their systems to support direct dialing of 911 so that a user does not need to add any prefix or access code such as the number quot9quot Then MLTS installers managers and businesses operating these systems must ensure that once they are in place they support 911 direct dialingKari39s Law and the FCC39s rules also include a second requirement to help ensure first responders can gain access to the premises after a 911 call is placed on a MLTS The system must be configured to notify a central location onsite or offsite where someone is likely to see or hear the notification Acceptable forms of such notification include conspicuous onscreen messages with audible alarms for security desk computers text messages for smartphones and emails to administratorsThese notifications sent to an MLTS owner39s central location must include three components the fact that a 911 call has been made a valid callback number and information about the caller39s location The FCC recognized that manufacturing or installing equipment that provides a callback number or location information to the central location can prove very challenging so it has provided an exception to the central notification requirement if the MLTS operator can demonstrate that it is technically infeasible for particular devices or the system to provide a callback number or location informationUnder RAY BAUM39S Act the FCC has adopted a third requirement to ensure that quotdispatchable locationquot is conveyed with 911 calls to dispatch centers The quotdispatchable locationquot requirement means that even more detailed information must be delivered to the first responders39 dispatch center with every 911 call The information must include the validated street address of the calling party plus a suite or apartment number or similar information that adequately identifies the calling party39s whereabouts within the larger building Just as with the requirement under Kari39s Law for devices to notify a business39 central location when they call 911 the quotdispatchable locationquot requirement also has a quottechnical infeasibilityquot exception for nonfixed devices whether used on the business39 premises or not With recent improvements in technology however it is becoming harder and harder for businesses that need to update or replace their MLTS to argue that the 911 requirements are quottechnically infeasiblequotIn the little over a year that the FCC39s full complement of MLTS 911 rules have become effective there have not been publicly reported enforcement cases in which the FCC has pursued or sanctioned a noncompliant MLTS system In the coming months however the FCC can be expected to take any violations that it uncovers very seriously particularly if they come to light in an emergency situation in which first responders were unable to properly assist a victim because of deficiencies in the MLTS system over which the emergency call was placedThis column was written by Anne Swanson Partner Wilksinson Barker Knauer DCClick the social buttons to share this content with your friends and colleaguesThe opinions and points of view expressed in this content are exclusively the views of the author andor subjects and do not necessarily represent the views of MediaVillagecomMyersBizNet Inc management or associated writers

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New Multi-Line Telephone Systems at All Businesses Now Subject to FCC 9-1-1 Requirements

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New Multi-Line Telephone Systems at All Businesses Now Subject to FCC 9-1-1 Requirements

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