September 12, 2023
It’s been a few years since we last wrote about two federal statutes that bolster emergency 9-1-1 calling in buildings with on-prem, cloud or hybrid multi-line telephone systems (MLTS): Kari’s Law and Section 506 of RAY BAUM’S Act. They went into effect for all 50 states in early 2018 and early 2021, respectively, and soon thereafter covered millions of remote workers as well.
As of early 2022, the Federal Communications Commission began bringing the hammer down (at least in word) for non-compliance, including a one-time fine of $10,000 and penalties of up to $500 per day. (The total amount of penalties and fines levied so far doesn’t appear to be publicly available information). Particularly for small and even medium-size businesses and institutions – schools included – that’s no drop in the proverbial bucket.
So, if your business isn’t yet compliant, it’s a good idea to start the process now. Not only is it the responsible thing to do, it’s ultimately cheaper than shelling out $3,500 a week if you’re flagged for non-compliance. In case you’re wondering, that’s $182,000 a year.
Even so, according to this August 2023 story in Campus Safety Magazine, “some experts predict fewer than 10 percent of organizations, including educational institutions, are in compliance despite 80 percent claiming they are. Another expert, Mark Fletcher, vice president of safety solutions at 911inform (he’s also an author and proponent of Kari’s Law), pegs the number of non-compliant orgs at “less than 50 percent.” That’s still far more than it should be.
“There have been polls done across the industry. Self-reporting, 60 percent say they are compliant,” Fletcher said. “Now, that’s someone being asked, ‘Are you compliant with a law that’s federally mandated and exposing you to massive liability?’ You’re not going to get a lot of people that say they aren’t.”
Last May, in Illinois, legislation that complements Kari’s Law and RAY BAUM’S Act was signed into law. House Bill 5502, sponsored by Illinois senator Bill Cunningham, further streamlines the 9-1-1 calling process so it’s easier for callers (especially children) to dial out and reach responders in an emergency. According to an article on Cunningham’s website, “Under the new law, MLTS vendors and manufacturers must configure new systems to support direct dialing 911.” So, if you’re located in Illinois, that’s something else to consider on your journey toward compliance.
“There are obligations for everyone, from the manufacturer and distributor through to the operator of any multiline telephone system,” Martha Buyer, a telecommunications attorney, said of E911 compliance in a blog post on TechTarget.com.
“In addition to addressing the technical aspect of compliance,” the article went on to summarize Buyer’s advice, “it’s important for organizations to regularly meet with emergency responders to establish the information that would be most useful to them. Location information that might make sense to an HR or IT team, such as cubicle designations, may not be as helpful for emergency responders.”
And this: “Organizations also need to be aware of how new technology could affect compliance with Kari’s Law and RAY BAUM’s Act. For example, one trend Burch said he was starting to see was enterprises deploying their own private wireless networks to replace a Wi-Fi network. In that scenario, the enterprise is providing the network, which could mean compliance requirements for 911 location information.”
It’s crucial to understand your MLTS. If you’re not sure how or if Kari’s Law or RAY BAUM’s Act or the recently enacted Illinois law impact your organization, your friendly neighborhood MSP (perhaps Mindsight) can offer valuable insight that could save you from paying penalties and will make your systems as effective as possible.
Emergencies arise all the time, as evidenced by the nearly quarter-billion 9-1-1 calls placed in the U.S. each year. Making your E911 systems fully compliant, if they aren’t already, may well save lives.
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