Get Educated Now: New E911 Compliance Requirements

Do you know what happens when your employees dial 911?

In an emergency situation, your employees may dial 911 to get the help they need. Did you know that your communication environment can control the level of detail and accuracy provided to dispatchers and emergency responders about your location? With the right parameters in place, you can improve your employees’ safe communication abilities. New legislation around Enhanced 911 (known as E911) technology mandates it. Read on to make sure you understand the requirements.

The Difference Between 911 and Enhanced 911 (E911)

911 sends calls to your local Public Safety Answering Point (PSAP), also known as your 911 dispatcher. Then, PSAP engages the appropriate police, fire, or ambulance services.

With E911, the 911 call is routed to the local PSAP based on Automatic Number Identification (ANI). ANI information and provides location information based on an ALI database to the PSAP operator.

Enhanced 911 was created to provide more accurate location information, along with a callback number, to the PSAP. This location and caller data has proven success in saving lives in emergency situations.

The New Standards: Kari’s Law & Ray Baum’s Act

There are two federal laws going into effect: Kari’s Law and Ray Baum’s Act. Each law has specific requirements and compliance expectations for corporate teams.

Kari’s Law: Enabling Direct 911 Dialing

Kari’s Law requires businesses to enable direct dialing of 911, without prefix or other digits required. (Businesses may provide additional patterns, such as 9911.) Kari’s Law also requires an on-site notification of the 911 call that includes the details of the dispatchable location, to decrease response time. Kari’s Law went into effect in February 2020.

What does this mean for your organization? It means that any 911 calls need to be sent out to 911 Services without any delay or prefix. Users within the organization need to be able to walk up to any phone, dial 911, and reach a 911 dispatcher outside of the organization. In addition, a notification of said calls needs to be sent to a central point of contact in the organization where the notification will be heard or seen (such as a front desk). This notification can be sent in many formats, as long as the notification does not delay the 911 call:

  • Computer application

  • Text message

  • Email

  • Other type of notification system

It is best to send the notification simultaneously, but it can be sent after the 911 call if sending simultaneously is not technically feasible. The callback number presented in the PSAP ALI database must be associated to an ELIN (Emergency Location Identification Number) that matches location information for the caller. This is a DID (Direct Inward Dial) number that the PSAP can call to reconnect with the caller if the call is disconnected or more information is necessary from the caller.

Ray Baum’s Act: Ensuring an Accurate Dispatchable Location

The second law is Ray Baum’s Act, which requires organizations to ensure that every 911 call conveys a dispatchable location and callback number to the PSAP (the 911 dispatcher). Organizations must comply with Ray Baum’s by January 6, 2021 for fixed locations and by January 6, 2022 for non-fixed locations.

A dispatchable location by definition is “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.” Dispatchable locations need to be determined by the organization on how best to direct emergency responders to the correct location of the individual in need of emergency services. This rule applies to 3 different types of devices:

  • Fixed MLTS (multi-line telephone system) calls: These are stationary devices that do not move within the organization. They must provide a “dispatchable location” to the PSAP.
  • Non-fixed MLTS calls: These are devices inside the organization that will move, such as a soft phone or wireless phone. They may provide alternate location information to the PSAP.
  • Off-premises, non-fixed calls: These are devices that connect to the system from a remote site. They are outside of the organization’s control and rely on the end user for location information.

What does this mean for your organization? It means that, in some cases, more than just an address will need to be given to the PSAP when making a 911 call. This completely depends on the layout of the building and proper signage on premises.

For example, if the user dials 911 from a conference room on the 5th floor, how will dispatch know where to find that emergency if only a street address is given? In the case of a multi-floor building, floor number should also be given to the PSAP. Depending on the size of the floor, is the conference room easily identified with signage? If not, maybe a directional or room number will also need to be presented. Ray Baum’s Act is intended to get the emergency responder to the emergency site as quickly as possible.

How To Know If Your System Is Affected

These laws apply to any phone system installed, sold, or leased after February 16, 2020: on-premises, cloud, or hybrid.

If your current system was installed pre-2/16/2020, you do not have to be in compliance. However, it is highly recommended to keep up with these federal regulations. They improve the safety of all employees.

Many U.S. states have state-level E911 laws in place: check out our list of state-by-state requirements below. Kari’s Law and Ray Baum’s Act are federal laws. They must be followed if your state laws are non-existent or not as strict as these federal regulations.

Planning for Compliance: Three Key Considerations

If you are deploying a new phone system, you must meet the requirements for Kari’s Law. Ray Baum’s Act takes effect in 2021, but we recommend planning for compliance now. Take these important factors into consideration when designing your new system:

Dial Plan and 911 Call Routing

  1. Distributed vs. Centralized 911 Calling When introducing centralized call paths, consideration for local 911 routing in the event the centralized path is not available needs to be taken into consideration. In these scenarios, a local PSTN circuit to the location is highly recommended.
  2. Impact of Direct 911 Dialing to Your Dial Plan In most MLTS systems, internal extensions and DIDs are in use – sometimes one more than the other. What prefix is being used to access the PSTN? A large majority of organizations use 9 to access the PSTN, but others also use 7, 8 and other digits to access PSTN. This can sometimes alleviate confusion when dialing 911 as a common mistake when using 9 to dial outbound is a user will dial 91 to start dialing a long distance call, then accidentally dial a second 1 when typing out the 10-digit number. This dial mistake results in a call to 911. If the user panics and hangs the call up before the dispatcher answers, emergency services could still be dispatched as well as your business being hit with a fine. If a PSTN access code of 9 is in use, this mistake can be avoided with proper end user training. Standard protocol if a user does accidentally dial 911 would be to simply stay on the line and explain that the call was an accident and that they do not have an emergency. Another part of the dial plan to think about are user extensions and feature access codes. Do any of these start with 9? If so, the system might be subjected to a timeout leaving users confused. It would be best to not have any user extensions begin with 9 for this reason. Consider expanding the amount of digits for user extensions so they don’t begin with 9 or change the range for feature access codes to something else.

E911 Zones: Signage, Naming, and Assignment

  1. In-Building Directional SignageIf a new individual enters your business, how easily can they find their way around with current signage? Is there a receptionist that assists with finding the right locations, people, and offices? If it is difficult for someone to navigate with current signage and personnel, consider improvements. Alternatively, you can implement a workflow where someone who received the central notification meets the dispatchers at the proper entrance and directs them to the emergency.

  2. Internal Zone Creation and Naming

    If your organization is a multi-floor building or multi-building campus, consider providing floor number and building number or name with the location information included in the PSAP database. Directional information can help too (e.g. North, South, Billing Department, etc.).

  3. “Phone-to-Zone” Assignment If your new system is IP-based, users have the ability to physically move their IP phones within your campus. As an administrator, this can be a location-tracking nightmare. Ideally, you should track these IP-based phones based on network or zone tracking (vs. user phone number).

E911 Notifications: Assignment, Format, and Delivery

  1. Central Notification Assignment Have you identified the best person and/or location to receive 911 notifications internally? Ideal options are usually front desk personnel, security group, onsite emergency response teams, system administrators, or office managers.

  2. Notification Format and Delivery Method

    There are many third-party technologies available to achieve the 911 notification, in numerous ways. You’ll want to consider how your designated notification recipient operates on a daily basis. Are they sitting at a computer? Are they roaming with a wireless device or cell phone? Do they only have a desk phone available to them? Answering these questions will help you determine the right notification format: desktop, SMS text message, phone call, or email.

E911 Laws by State

Many states have established their own unique requirements for E911 compliance regulations. Our chart shows these state-by-state differences. It’s important to remember that in cases where state-specific requirements do not exist or are not as strict as the federal guideline, the federal guideline must be followed above all:

Federal E911 Guidelines: The dispatchable location must be conveyed with a 9-1-1 call, regardless of the technological platform used and including with calls from multi-line telephone systems. This means every 9-1-1 call requires adequate location information, which typically means the street address of the calling party, and additional location information such as floor and room number.

STATEREGULATIONS
AlabamaNo state-specific legislation. Refer to federal E911 regulations for guidance.
AlaskaA municipality may require an Enteprise Communications Server operator to provide enhanced 911 service. AS 29.35.134. Multi-Line Telephone Systems.
ArizonaNo state-specific legislation. Refer to federal E911 regulations for guidance.
ArkansasEnterprise Communications Server operators must deliver to the PSAP the phone number and street address of any telephone used to place a 911 call. Ark. Code Ann. 12-10-303 (1997).
CaliforniaCalfornia E911 Legislation is pending.
ColoradoEnterprise Communications Server operators shall provide written information to their end-users describing the proper method of dialing 911, when dialing an additional digit prefix is required. ECS operators that do not give the ANI, the ALI, or both shall disclose this in writing to their end-users and instruct them to provide their telephone number and exact location when calling 911. Sec. 1. 29-11-100.5, Colorado Revised Statutes.
ConnecticutA private company, corporation or institution may provide private 911 service to its users, provided it has adequate resources, the approval of the Office of State-Wide Emergency Telecommunications and the municipality in which it is located, and a qualified private safety answering point. CT Statute 28-25b.
DelawareNo state-specific legislation. Refer to federal E911 regulations for guidance.
District of ColumbiaNo state-specific legislation. Refer to federal E911 regulations for guidance.
FloridaAll PBX systems installed after January 1, 2004 must be able to provide station-level ALI data to the PSAP. Section 365.175, Florida Statutes 2009 365.175.
GeorgiaNo state-specific legislation. Refer to federal E911 regulations for guidance.
HawaiiNo state-specific legislation. Refer to federal E911 regulations for guidance.
IdahoNo state-specific legislation. Refer to federal E911 regulations for guidance.
IllinoisRequirements vary based on residential vs. business and square footage. Private residential switch service providers must identify the telephone number, extension number, and the physical location of a 911 caller to the PSAP. Private business switch service providers must provide ANI and ALI data for each 911 call. Also, they must not require the dialing of an additional prefix (Kari’s Law, systems installed after July 1, 2015). Generally, a distinct location needs to be provided per 40,000 ft2 or each entity sharing a building. (Full Legislation PDF also includes City of Chicago E911 legislation requirements). 50 ILCS 750/15/5 et seq.

Kari’s Law: ECS operators must not require the dialing of any additional digits to access 911, effective after July 2015.

IndianaNo state-specific legislation. Refer to federal E911 regulations for guidance.
IowaNo state-specific legislation. Refer to federal E911 regulations for guidance.
KansasNo state-specific legislation. Refer to federal E911 regulations for guidance.
KentuckyResidential private switch telephone service providers located in E911 capable areas must provide ANI and ALI data for each 911 call, and must provide ALI that includes the street address, plus an apartment number or floor, if applicable. 65.752 Statutes.
LouisianaPBX systems installed after January 1, 2005 must be capable of providing station level ALI (Automatic Location Identification) to the PSAP. RS 33:9110.
MaineResidential ECS providers must deliver a distinct ANI and ALI for each living unit to the PSAP. Business ECS providers must deliver ANI or ALI to the PSAP; specific ALI data requirements are outlined. Also includes requirements for hotels/motels, exemptions and guidelines to establish a private emergency answering point. State of Maine – MLTS installed or upgraded after July 27, 2005 require a minimum of one ANI/ALI per floor, per 40,000 square feet. 25 MRSA 2934.
MarylandMaryland does not currently have E911 legislation in place for multi-line telephone system operators (MLTS).

Maryland has enacted Kari’s Law: ECS operators must not require the dialing of any additional digits to access 911 as of December 31, 2017. H.B. 1080

MassachussettsAs of July 1, 2009, all new or substantially renovated ECS such as Centrex, PBX and hybrid telephone systems must route emergency calls to the appropriate PSAP and provide ANI and ALI for every 911 call. The level of detail required for ALI data and exemptions are outlined as well. 560 CMT 4.00 et seq.
MichiganRequirements vary based on number of buildings and square footage. Generally, the specific location of each communications device needs to be provided unless an alternative method of notification and adequate means of signaling and responding to emergencies is maintained 24-hours a day. MLTS operators in violation of the act after December 31, 2011 may be assessed a fine by the Michigan Public Utilities Commission from $500.00 to $5,000.00 per offense. * E911 legislation is currently in effect in Michigan with a compliance deadline of December 31, 2019. – MCL 484.901 et seq.
MinnesotaOperators of ECS purchased after December 31, 2004 must ensure that their system provides ANI and ALI for each 911 call. Residential ECS should provide one distinctive ANI and one distinctive ALI per residential unit. Location identification requirements for businesses are outlined. Also includes requirements for hotels/motels, schools, exemptions and guidelines to establish a private emergency answering point.
MississippiService providers must provide callers with access to the appropriate PSAP. Anyone operating a shared tenant service is required to provide the ANI and ALI for each 911 call made from any extension. MS SEC. 19-5-359.
MissouriNo state-specific legislation. Refer to federal E911 regulations for guidance.
MontanaNo state-specific legislation. Refer to federal E911 regulations for guidance.
NebraskaNo state-specific legislation. Refer to federal E911 regulations for guidance.
NevadaNo state-specific legislation. Refer to federal E911 regulations for guidance.
New HampshireCurrently, there is not an enacted bill of legislation which required E911 for the State of New Hampshire. However, the New Hampshire has many regulations pertaining to MLTS. “When putting all of these regulations together, it is the opinion of the State of New Hampshire that each phone number is required to have accurate location information, including apartment, suite and floor information”.- State of New Hampshire – Department of Safety, Division of Emergency Services and Communications
New JerseyNo state-specific legislation. Refer to federal E911 regulations for guidance.
New MexicoNo state-specific legislation. Refer to federal E911 regulations for guidance.
New YorkKari’s Law: ECS operators must not require the dialing of any additional digits to access 911, as of May 24, 2017.
North CarolinaNo state-specific legislation. Refer to federal E911 regulations for guidance.
North DakotaNo state-specific legislation. Refer to federal E911 regulations for guidance.
OhioNo state-specific legislation. Refer to federal E911 regulations for guidance.
OklahomaKari’s Law: Business owners or operators using VoIP service must allow a 911 call on the system to directly access 911 without an additional code, digit, prefix, postfix, or trunk-access code, and must provie a notification to a central location when someone on their network dials 911. Effective January 1, 2017
OregonNo state-specific legislation. Refer to federal E911 regulations for guidance.
PennsylvaniaShared residential ECS operators must deliver 911 calls to the PSAP with one distinctive ANI and ALI for each living unit. Business ECS operators must deliver the 911 call with an ANI and ALI detailed to the building and floor location of the caller, or must establish a private emergency answering point. 35 PCS 5302 et seq.
Rhode IslandNo state-specific legislation. Refer to federal E911 regulations for guidance.
South CarolinaNo state-specific legislation. Refer to federal E911 regulations for guidance.
South DakotaNo state-specific legislation. Refer to federal E911 regulations for guidance.
TennesseeKari’s Law: ECS operators must not require the dialing of any additional digits to access 911 as of April 2016.
TexasECS operators who serve residential users and facilities must provide the same level of 911 service as received by other residential users in the same regional plan area, including ANI. Additionally, business owners or operators using VoIP service must allow a 911 call on the system to directly access 911 without an additional code, digit, prefix, postfix, or trunk-access code (Kari’s Law) and must provide a notification to a central location when someone on their network dials 911.

The state of Texas requires E911 for residential MLTS. In Tarrant County, ECS providers offering residential or commercial service to non-affilitated businesses must provide the level of 911 service as required under the appropriate regional plan. Businesses must provide the PSAP with ANI and ALI data for each 911 call. TX Health and Safety Code, CH. 771aAdditionally, the State of Texas enacts 9-1-1 legislation by county and each county has a 9-1-1 or emergency service coordinator that can be contacted for specific 9-1-1 requirements in the County.

UtahAny owner or operator of a multi-line telephone system added or upgraded after July 1, 2017, shall configure the MLTS system to include the street address, and if applicable, the business name, of the location of the communications device from which the call is made. Additionally, callback number, office, unit or building number, room number, and if multi-story, building floor. Utah Code Secs. 53-10-601 et seq.
VermontPrivately-owned telephone system operators must provide ANI signaling and station-level ALI data to the PSAP. 30 V.S.A. 7057.
VirginiaAll PBX/MLTS installed after July 1, 2009 must ensure that an emergency call placed from any telephone number is delivered to the PSAP with ANI and ALI, or an alternative method of providing call location information has been approved. VA Code 56-484.14.
WashingtonResidential service providers must ensure that an emergency call placed from any caller is delivered to the PSAP along with a unique ALI for their unit. Business service providers must ensure that an emergency call placed from any caller is delivered to the PSAP along with a unique ALI for their telephone (Businesses occupying over 25,000 ft2, more than one floor or multiple buildings need to provide automatic location identification in a format compatible with local 911 system RCW 80.36.560, RCW 80.36.555).
West VirginiaNo state-specific legislation. Refer to federal E911 regulations for guidance.
WisconsinNo state-specific legislation. Refer to federal E911 regulations for guidance.
WyomingNo state-specific legislation. Refer to federal E911 regulations for guidance.

Getting Started With Compliance

Colorado Beach works with mulitple vendors that can help with ensuring your organization’s technical compliance. From native capabilities in Cisco Unified Communications Manager (CUCM), to enhanced capabilities with manufacturers like Singlewire and RedSky – our collaboration consultants can help you navigate options and create a roadmap towards achieving federal compliance.

Even if you aren’t immediately affected by these dates with a new install or migration, these E911 laws are helping to improve emergency calling in all organizations. Phone systems are changing and providing many new and amazing features that enable the workforce to work smarter every day. Shouldn’t these advances extend to emergency calling?

Our team is happy to advise your enterprise on technology updates to meet E911 regulations. Contact our team to schedule a discovery session.