E911 Compliance Summary:

• Enhanced 911 (E911) provides more accurate location information and a callback number to PSAP.

• E911 compliance means meeting Kari’s Law & Ray Baum’s Act, two federal laws that set standards for on-premises, Cloud, or hybrid MLTS installed, sold, or leased after February 16, 2020. See more details about each law here.

• It is highly recommended that all systems, even the exempt pre-2/16/2020 systems, are updated to be compliant with federal laws to keep your employees safe.

• Some states have their own Enhanced 911 legislation, view the detailed table here.

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 communications environment can aid in controlling the level of detail and accuracy provided to 911 dispatchers and emergency responders about your location? With the right parameters in place, you can improve your employees’ safe communication abilities.

In fact, recent legislation around Enhanced 911 (known as E911) technology mandates it. Read on to make sure you understand the requirements as they may apply to your organization’s on-premises, Cloud, or hybrid multi-line telephone systems (MLTS).

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 two federal E911 laws that are in effect are Kari’s Law and RAY BAUM’S Act. These laws are applicable to any on-premises, Cloud, or hybrid MLTS installed, sold, or leased after February 16, 2020. There is admittedly some potential gray area when interpreting some of the requirements.  As such, it is imperative that you work with your organization’s legal team regarding interpretation and adherence to the laws in the context of your communications environment regarding E911 standards and compliance. Nonetheless, the purpose behind these laws is to improve emergency services’ response time to save lives.

Kari’s Law: Enabling Direct 911 Dialing

Kari’s Law requires businesses to enable direct dialing of 911, without prefixes or requiring other digits as part of the dialed string. (Businesses may provide additional patterns, such as 9911, but 911 must be configured as routable to the PSAP.) Kari’s Law also requires an on-site notification in parallel with the outbound 911 call that includes the details of the dispatchable location. 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 or security team). The intent behind the notification requirement is for personnel from the organization to be aware that someone has dialed 911 to assist (if possible) the individual who dialed 911, and to aid the dispatched emergency responders in getting to the exact location of the individual in distress.

The notification – at a minimum – must include the following pieces of information:

• The fact that a phone has dialed 911

• A callback number for the phone that called 911

• The location of the phone that called 911

The notification can be sent in many formats, as long as it does not delay the 911 call:

• Computer application

• Text message

• Email

• Other types of notifications(e.g. alerts on smartphones, visual pop-ups on IP phones, digital signage, and even overhead paging)

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 with an ELIN (Emergency Location Identification Number) that matches the 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 if 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 locations. There were staggered deadlines for organizations between 2021 and 2022 regarding device types (fixed vs. non-fixed devices) and compliance; however, as of January 6, 2022, RAY BAUM’S act is now fully in effect.

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 softphones or wireless phones. 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 location. They are outside of the organization's control and rely on the end user for location information – for example – work from home personnel who are using a softphone endpoint (e.g. Cisco Jabber, Microsoft Teams or Webex clients)

What does this mean for your organization? It means that, in all cases, more than just an address needs to be presented to the PSAP when making a 911 call as a dispatchable location is also required.  The level of detail of the dispatchable location depends on the layout of your location(s) and what is going to best enable emergency responders to quickly get to the individual(s) in distress.  To further aid dispatched emergency responders, display floor plans with defined dispatchable locations (E911 zones) and prominent signage are highly recommended.

For example, if a user dials 911 from a conference room on the 5th floor of your organization’s headquarters, how will dispatch know where to find that emergency if only a street address is given? In the case of a multi-floor building – at the very minimum – the floor number should also be given to the PSAP (in addition to the street address). 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 as part of the dispatchable location data. Ray Baum’s Act is intended to aid in getting emergency responders to the location of the individual(s) in distress as quickly as possible.

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 may 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 enacted state-level E911 laws as well: please review a matrix of state-by-state requirements. Keep in mind that 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.

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 redundant local PSTN circuit deployed at the location(s) 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, and your business will be 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 is 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 number 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 Signage

If 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 may 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), so that dynamic endpoint moves can be accounted for in advance and by design

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 Validation: Keeping E911 Data Current

Let’s say that at one time your organization’s communications system was configured to be compliant with federal and state E911 laws.  Are there processes in place to validate 911 dialing, the corresponding address and location data that is presented to the PSAP, and the functionality of alerting requirements? Here are some frequent recommendations that we make to customers to ensure that their MLTS system and corresponding E911 data is accurate and in compliance:

1. Stay up-to-date on federal and state E911 laws.

   Both federal and state E911 requirements will only continue to evolve.  It’s important to be aware of any updates and to raise them to your legal and IT teams’ attention for their guidance.

2. Determine which PSAPs handle the 911 calls outgoing from your location(s).

   Each PSAP has specific E911 testing requirements (e.g. E911 testing only during non-peak hours, a limited number of E911 test calls a day, and a published non-emergency number to call to schedule testing).  Furthermore, certain PSAPs provide services where organizations can digitally send them floor plans of the locations with marked zones so that the dispatched emergency resources already have in hand a visual representation of where they are going onsite.

3. Develop standards within your organization.

   Determine how often to complete E911 zone testing (to validate location address/location/ELIN information, ELIN call back functionality as well as onsite alert recipients).

   E911 service providers typically provide a non-emergency number that can be dialed (e.g. 933) to validate the address, location, and ELIN information without the call actually routing to the PSAP.  This is a great resource to initially validate the information prior to placing a test 911 call. The non-emergency verification number should not be used for final validation; the true test is placing a 911 call to the PSAP for them to confirm the information.  When placing test 911 calls to the dispatcher, ask them to verify the following pieces of information: address, location, ELIN, and caller ID/caller name. 

4. Develop a strategy and education plan for your E911 notification recipients.

   Spend ample time educating your onsite alert recipients, so that they know your organization’s policy for what to exactly do when a user dials 911. The justification behind onsite alerts is to raise awareness at the organization where the 911 call originated and to allow for the notification recipient(s) to be able to help direct the dispatched emergency response team to the appropriate location. For example, unlocking the appropriate doors and meeting emergency responders upon arrival will help expedite their ability to arrive at the specific location of the 911 call as quickly as possible.

Let’s say that at one time your organization’s communications system was configured to be compliant with federal and state E911 laws.  Are there processes in place to validate 911 dialing, the corresponding address and location data that is presented to the PSAP, and the functionality of alerting requirements? Here are some frequent recommendations that we make to customers to ensure that their MLTS system and corresponding E911 data is accurate and in compliance:

1. Stay up-to-date on federal and state E911 laws.

   Both federal and state E911 requirements will only continue to evolve.  It’s important to be aware of any updates and to raise them to your legal and IT teams’ attention for their guidance.

2. Determine which PSAPs handle the 911 calls outgoing from your location(s).

   Each PSAP has specific E911 testing requirements (e.g. E911 testing only during non-peak hours, a limited number of E911 test calls a day, and a published non-emergency number to call to schedule testing).  Furthermore, certain PSAPs provide services where organizations can digitally send them floor plans of the locations with marked zones so that the dispatched emergency resources already have in hand a visual representation of where they are going onsite.

3. Develop standards within your organization.

   Determine how often to complete E911 zone testing (to validate location address/location/ELIN information, ELIN call back functionality as well as onsite alert recipients).

   E911 service providers typically provide a non-emergency number that can be dialed (e.g. 933) to validate the address, location, and ELIN information without the call actually routing to the PSAP.  This is a great resource to initially validate the information prior to placing a test 911 call. The non-emergency verification number should not be used for final validation; the true test is placing a 911 call to the PSAP for them to confirm the information.  When placing test 911 calls to the dispatcher, ask them to verify the following pieces of information: address, location, ELIN, and caller ID/caller name. 

4. Develop a strategy and education plan for your E911 notification recipients.

   Spend ample time educating your onsite alert recipients, so that they know your organization’s policy for what to exactly do when a user dials 911. The justification behind onsite alerts is to raise awareness at the organization where the 911 call originated and to allow for the notification recipient(s) to be able to help direct the dispatched emergency response team to the appropriate location. For example, unlocking the appropriate doors and meeting emergency responders upon arrival will help expedite their ability to arrive at the specific location of the 911 call as quickly as possible.

Many states have enacted their own unique laws for E911 compliance regulations. The below matrix details the state-by-state requirements. It’s important to remember that in cases where state-specific laws 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.

Burwood represents many vendors that can help with ensuring your organization’s technical compliance. From native capabilities in Cisco Unified Communications Manager (CUCM) and Cisco Emergency Responder (CER) to enhanced capabilities from E911 vendors such as RedSky, Intrado, and 9Line, - our collaboration consultants can help you navigate options and create a roadmap toward achieving federal and state compliance.

These E911 laws are helping to improve emergency calling in all organizations by not only raising internal awareness when 911 is dialed via notifications, but also by striving to expedite the time it takes for emergency responders to arrive at the scene where individuals are in distress by requiring dispatchable locations. On-premises, Cloud, and hybrid 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 calls?

Burwood’s team is happy to advise your enterprise on technology updates to be E911 compliant. Contact our team to schedule a discovery session.

Burwood Group strongly recommends compliance with United States Federal and State E911 laws; however, we cannot offer legal advice. In addition to contacting a qualified provider, we recommend you work with your legal team to finalize your E911 standards.

Updated: July 14, 2023