Melissa Swartz ¦ October 30, 2019


Effective February, 2020, new FCC rules and federal laws will govern 911 calling.  Compliance is mandatory for businesses that use multi-line telephone systems (MLTS).  Any business with more than one phone line, that uses a phone system, will be affected.


Are you ready?


  1. Kari’s Law requires MLTS that are manufactured or installed after February 16, 2020 to:
      • Enable users to dial 911 directly, without having to dial a prefix such as “9” to reach an outside line.
      • Provide for notification (e.g., to a front desk or security office) when a 911 call is made so long as the system can be “configured to provide such notification without an improvement to the hardware or software of the system.”.
  1. RAY BAUM’S Act of 2018* requires that:
      • The 911 call convey a “dispatchable location” to the 911 call centers, so that the public safety access point (PSAP) will receive the caller’s location automatically and can dispatch responders more quickly.


“Dispatchable location” is defined 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.”


This is especially important in situations presented by campus environments and multi-story buildings. Some states have passed laws requiring varying levels of detail about the location of someone placing a 911 call. However, this is the first federal law.


It’s important to understand that station-specific information is NOT required at this time.  Some vendors were pushing for this level of detail to be mandatory, because they have “solutions” that provide this information and would profit from such a requirement. However, the final law requires less specific information.


The actual information required as a “dispatchable location” will likely be defined by the courts eventually.


Workplace Safety Considerations and Risk


“Employers have an absolute obligation to provide a safe workplace” according to Martha Buyer, telecom attorney and 911 expert. She recommends that organizations work with first responders to determine what information the responder will find most useful in an emergency when seconds count.


She adds, “It wouldn’t even take a great lawyer to make a strong argument that the absence of access to accurate and reliable 9-1-1 information creates an unsafe workplace, thus placing significant liability on employers who have chosen, for any number of reasons (some of which might even be legitimate) not to take the reasonable steps necessary (here, “reasonable” is a legal term of art) to ensure a safe workplace.”


“Additionally, employers who have employees in multiple states are obligated to treat employees in different locations similarly”, Martha notes.  Some states have specific requirements for the level of location detail required for 911 calls.  If an employer is complying with the requirements in one state, they must take the steps necessary to provide sufficiently and similarly detailed information in all states where employees are located, regardless of the requirements of those states.


Martha recommends that decisions about managing 911 location information should be expanded beyond the IT and Communications departments to include representatives from areas such as Risk Management, Legal, Finance, and Facilities (or any other departments that will bring useful ideas to the table). In this context, the more input there is from more departments, the more likely the outcome will reflect the input of those who may be most critically affected.


* Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018 (H.R. 4986)