Federal Regulations Affect ALL Businesses Nationwide: Must Comply with Kari’s Law and the RAY BAUM Act
Important deadlines are coming up for all businesses nationwide that use MLTS, or Multi-Line Telephone Systems. This term, MLTS, includes all types of phones ranging from hardphones kept at a work desk to soft phones that travel with an employee on their laptop. So, if your organization provides communication devices to employees, these deadlines apply to you!
It is important to understand our communication devices as not only collaborative tools for work purposes, but also as active lifelines to 9-1-1 services should someone have an emergency. The Federal Communications Commission (FCC) has worked to establish rules and regulations that make sure our technology helps us in emergency situations, rather than hinder our access to emergency services.
In August 2019, the FCC established rules and set compliance deadlines for both Kari’s Law and the RAY BAUM Act. The deadline has already passed for Kari’s Law, which outlines direct dialing and notification requirements. When assessing your organization to prepare for compliance with the RAY BAUM Act, double check that your organization is already compliant with Kari’s Law. If not, ensure your steps toward compliance with the RAY BAUM Act also bring you into compliance with Kari’s Law.
What Does the RAY BAUM Act Require for Enterprises?
Simply, Section 506 of the RAY BAUM Act was developed in order to more accurately and efficiently find individuals who dial 9-1-1. The FCC decided that the best way to address this was to require organizations to automatically provide emergency call centers, or Public Safety Answering Points (PSAPs), with “dispatchable location” information alongside every emergency call placed from their network. We will discuss exactly how “dispatchable location” is defined a bit later, but for now, just think of it as an emergency caller’s exact location.
Dispatchable location was a necessary development because as technology has advanced, it has become a more dynamic undertaking to accurately locate emergency callers. For example, imagine you work in a downtown high-rise, on the 16th floor, in a closed-door office. If you were to have an emergency and dial 9-1-1, first responders would need more location information than a simple civic address. In order to reach you in the most efficient way, the dispatcher would need to communicate to the responders that you are on the 16th floor in office 1605.
The RAY BAUM Act ensures that this vital location information, your “dispatchable location”, is automatically communicated to emergency dispatchers in order for first responders to reach you as quickly and efficiently as possible.
So, What Is “Dispatchable Location”, Exactly?
Section 506 of the RAY BAUM Act defines “dispatchable location” as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.”
Clearly, this definition allows for a bit of flexibility in terms of determining what granularity of detail is appropriate in order for first responders to effectively locate a caller. Furthermore, these details are apt to change depending on the specific environment. Meaning, dispatchable location is not just one thing. It is dynamic.
If an individual dials 9-1-1 from a small café, perhaps a civic address is all the first responder would need to know to find the caller. However, like the example from above, if you are in a high-rise on the 16th floor behind a closed door, a first responder is going to need much more information to effectively find you.
This is why the FCC intentionally included flexible language around the definition for “dispatchable location”, as callers dial 9-1-1 from all kinds of locations. However, what is not flexible is the fact that if your business communicates via MLTS devices, and someone dials 9-1-1 from a device using your network, you will be responsible for that device automatically sending the caller’s “dispatchable location” to the PSAP. Meaning, your organization’s devices must be equipped to immediately convey the necessary location information to find a person who has dialed 9-1-1.
What Types of Phones Will Need to Deliver “Dispatchable Locations”…and WHEN?
The RAY BAUM Act includes ALL MLTS devices. This includes both static and nomadic phones that are either on-premise or move off-premise. It is important to take inventory of the types of phone systems your organization uses and how many of each kind you have. See the below graphic to determine the deadlines your organization must meet depending on the kinds of devices you use.
Static Phones (Hard Phones)
- Tangible phone that stays relatively fixed to the same place (at a desk, common area, reception)
- Can be on-premise (at the office, in the warehouse)
- Can move off-premise (desk phone taken back to home office)
Nomadic Phones (Soft Phones)
- Any device (laptop, tablet, smartphone) that has a soft phone client application
- Can be on-premise (bring a work laptop into the office everyday)
- Can move off-premise (work from home using your work laptop)
How Does My Organization Comply with the RAY BAUM Act and Provide Dispatchable Locations?
E911 solutions provided by third parties are generally required in order for organizations to become compliant with the RAY BAUM Act and to be able to automatically send adequate dispatchable locations of all enterprise devices.