Kari’s Law

ISPs should be aware of two new laws that went into effect in January. The first is Kari’s law. This law requires that all phone systems sold, leased or installed after February 16, 2020 must be pre-configured so that a user can directly dial 911 with no other dialing steps required. This law is aimed to bring the 911 system into buildings served by PBXs, keysystems, Centrex, and cloud-based VoIP. The intent is to improve 911 for places like hotels, universities, hospitals, and businesses. This law puts the responsibility to comply not only on phone system manufacturers, but also on anybody who installs, manages, or operates a voice system.

The law also creates new requirements on existing phone systems that went into effect on January 6. Phone systems must be configured so that any call placed to 911 will immediately notify a ‘central location’ that a call has been placed to 911. This must be implemented immediately for any existing phone system that can provide the notification without needing a software or hardware upgrade. The FCC believes that a large percentage of phone systems are capable of making such notifications, so those notifications must be activated. It’s worth noting that there is no exemption for small businesses – anybody operating a private phone system is expected to comply with the law. Interestingly, the law applies to outward-calling locations like an outbound call center that can’t receive calls.

The FCC leaves a lot of interpretive room in defining a ‘central location’ for delivering the notification. Their goal is that a notification of a call to 911 must be sent to a location where there is a high likelihood that somebody will see it. The FCC wants 911 centers to be able to contact somebody at a business to gain entrance and to hopefully locate the person that made the 911 call.

Notifications can be in any format including emails, text messages, pop-up notifications, alarms, etc. The new rules also require some ancillary information to be included in the notification, where technically feasible. This includes information like a callback number and as much information as possible about the location of the 911 caller (room number, the wing of building, etc).

To the extent possible this also applies to ‘mobile’ devices that are controlled by a phone system. This might include cordless phones used inside of a business or desksets that can be moved anywhere within the business. Companies are not expected to track commercial cellphones that aren’t on their system or the location of devices that are carried off-site.

The second law that went into effect in January is Ray Baum’s Act. One of the many provisions of this law requires that 911 centers be provided with ‘dispatchable location’ information. In plain English, that means that first responders want to know ‘the right door to kick down’ when responding to a 911 call. This goes into effect concurrently with Kari’s law and means that businesses must provide more information to 911 centers about how to respond to call made from their location.

This new law is also aimed at the same kind of buildings as Kari’s law – places like hotels or a business where a 911 responder doesn’t know how to locate the person that called 911. At a minimum, every call to 911 must convey a validated 911 street address. That’s routine information for calls made from single-family homes, but not necessarily so for a complex business like a hospital or business high-rise complex. If a validated 911 address can be conveyed today it must be done so. Businesses are given one year to implement this change and are expected to coordinate with 911 centers if they want to provide complicated information on room number, building layouts, etc.

The law also requires better reporting for mobile devices that are controlled by a phone system. The rules expect the notification to 911 to include the best information possible about the location of a caller with a mobile device such as a cordless phone. This could be as detailed as a room number or something less accurate such as the location of the nearest WiFi hotspot. Companies have two years to implement this change.

The changes that come from the Roy Baum Act are intended to be coordinated with the nearest 911 PSAP so that they understand the nature and quality of the location data when they get a call. Businesses are expected to notify, and test as needed, to make sure that PSAPs know how to locate callers at a business. The FCC has the ability to fine parties that don’t comply with the law, and so expect a few test cases within the next year when businesses fail to implement the new rules or else fail to convey information to their 911 center.