It’s Always Something
September 16, 2022
Seems there’s always something coming to 911, and while intentions may be good, it’s not always possible to follow through with immediate action.
In this case, the Federal Communications Commission (FCC) adopted a Report and Order on Aug. 1, 2019, that specifies the rules for Kari’s Law, and for Section 506 of RAY BAUM'S Act. Both laws are now in effect. Both affect access to 911.
Kari Hunt Dunn was murdered by her estranged husband in a Marshall, Texas (USA), hotel room. Kari’s daughter was present and, despite attempting to call 911 four times, she was not able to reach help because the hotel’s phone system required dialing “9” before any outgoing call could be placed.
Kari’s father, Hank Hunt, made it his job to ensure no one would ever experience the horror Kari’s daughter faced that day. He launched a campaign for change. His persistence resulted in Kari’s Law that was signed into federal law on Feb. 16, 2018.
There are two parts to Kari’s Law that affect businesses with multi-line telephone systems (MLTS) (typically found in office buildings, on campuses, in hotels).
Kari’s Law eliminates the need to dial additional numbers to reach 911. As of Feb. 16, 2020, MLTS vendors and manufacturers were mandated to configure new phone systems to support the direct dialing of 911.
Kari’s Law also requires MLTS organizations to implement notifications to on-site personnel that 911 has been dialed and from where it was dialed. These notifications can be via email, SMS/text, messenger service, or phone call. This will alert on-site personnel that there is an emergency so they can provide first aid, facilitate building entry by first responders, and escort emergency personnel to where they are needed.1
RAY BAUM'S Act
The RAY BAUM'S Act was primarily created to accurately locate 911 callers, regardless of the technological platform used.2 The FCC Report and Order requires that all MLTS phones automatically provide the PSAP with a “dispatchable location” of the caller. It is no longer enough for MLTS to merely report a street address. The MLTS must authorize automatic dispatchable location information when any user attempts to place a 911 call through a fixed device.3
Ray Baum joined U.S. Representative Greg Walden's staff as Staff Director on the Energy and Commerce Committee in December 2016. In this role in Congress, Baum worked closely with the FCC on telecommunications issues. Walden arranged to have RAY BAUM'S Act named in his honor.4
Organizations with MLTS must comply with the mandates of Kari’s Law by February 2020. The deadline for non-fixed phone lines and applications was Jan. 6, 2022. A year earlier, Jan. 6, 2021, was the deadline for businesses using certain fixed MLTS, interconnected Voice over Internet Protocol (VoIP), and telephony and telephony relay services.5
Any business or agency who does not comply with Kari’s Law and/or RAY BAUM'S Act could face a fine of up to $10,000 in addition to other penalties, including a fine of up to $500 each day they are found not in compliance.6
Compliance rates for either act is not available. However, compliance with the law requires a reasonable effort. This includes educating employees, contractors, and office guests on what the process for 911 compliance is. For example, organizations could issue a waiver to employees that explains that if they take a device home, dialing 911 may not provide accurate location information.7
As far as direct 911 involvement? Tracking compliance outside the PSAP is likely beyond the threshold of reasonable effort. After all, it’s always something.
1 “Kari’s Law and RAY BAUM'S Act: 911 Direct Dialing, Notification, and Dispatchable Location Requirements.” 911GeoFence. https://www.911geofence.com/911-law/mlts-911-requirements (accessed June 13, 2022).
2 “Multi-line Telephone Systems – Kari’s Law and RAY BAUM’S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements.” Federal Communications Commission. 2020; April 22. https://www.fcc.gov/mlts-911-requirements (accessed June 13, 2022).
3 See note 2.
4 “RAY BAUM'S Act: What is it and why does it matter?” Bandwidth. https://www.bandwidth.com/regulations/ray-baums-act/ (accessed June 13, 2022).
5 Bharadwaj K. “Dear GCs, CIOs and IT Leaders: Save the Date, January 6, 2022, for E911 Compliance Deadline.” Day Pitney LLP. 2021; Sept. 16. https://www.daypitney.com/insights/publications/2021/09/hlst-1-jan-6-2022-e911-compliance-deadline (accessed June 13, 2022).
6 See note 1.
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