Let’s Eat Grandma! or Let’s Eat, Grandma!

Punctuation is critical. Without a comma, an innocent child saying, “Let’s eat, Grandma!” is twisted into a questionable “Let’s Eat Grandma!”


While this internet meme has been going around for quite some time, just this last week I witnessed this identical lack of punctuation steering some of our valued customers in a direction of 9-1-1 remediation that was far more complex, and expensive, than what they were required to do; or what even made sense for their facility and specific situation.

Just after the NENA Model MLTS Legislation was published in 2008/2009, several states started their legislative process to implement legislation.

The legislative requirements that spelled out in Massachusetts 560 CMR 4.00 state:

The purpose of 560 CMR 4.00 is to establish regulations to carry out the provisions of Massachusetts General Legislature – Chapter 6A, §18J to require that, beginning July 1, 2009, any new or substantially renovated multi-line telephone system shall provide the same level of enhanced 911 service that is provided to others in the commonwealth.

There are a considerable number of definitions, which are often overlooked, but in reality define the embodiment of applicability, and this is where our customers were led astray. They were advised that section 4.04 of the law states:

4.04. Beginning July 1, 2009, each operator of a new or substantially renovated multi-line telephone system shall provide (1) a call back number; and (2) PSALI to the station level.

But they failed to advise the customer of two other important items; First the requirement of Callback to the ‘station level’ would seem to require a record for each and every station; however in the definitions section, Callback is clearly defined as being the station that called, OR: “[T]he number of a switchboard operator, attendant, or other designated onsite individual with the ability to direct emergency responders to the 911 caller’s location 24 hours a day, 7 days a weeks, 365 days a year.

The second issue is punctuation and the ‘period’ at the end of that sentence. It is actually a ‘semi-colon’ followed by the words, “; OR an ERL identifier.”, indicating that an Emergency Response Location zone is completely acceptable.

Zone Response to MLTS 9-1-1 was a concept introduced in October 2008 in the NENA 06-502 v1 Technical Information Document “Industry Common Mechanisms for MLTS E9-1-1 Caller Location Discovery and Reporting”.

It provides an appropriate level of granularity for Emergency Response when coupled with the Crisis Alert functionality or the enhanced On Site Notification functionality provided by DevConnect applications like SENTRY from Conveyant Systems. These solutions take all of the relevant additional data that exists about an emergency call event and correlates that information in an intelligent dashboard that internal first responders can utilize to formulate an appropriate response and coordinate with Police, Fire and Medical personnel that are also responding. Or the information can be put up on a display in the event the building is not manned.

By using an Over The Top delivery model on today’s network, or directly in-band on tomorrow’s NENA i3 compliant Next Generation 9-1-1 Emergency Services IP Network (ESINet), public safety will have all of the Big Data and the relevant information about an environment at their finger-tips facilitating faster emergency response, with the best possible resources. This isn’t the future, this is NOW, and we will be globally demonstrating it live as part of our Public Safety Solutions display at the 2016 Avaya Technology Forums in:

Bangkok, Thailand on February 25-26
Dubai, UAE on March 15 -17
Orlando, Florida on April 5 -7
Dublin, Ireland on May 10-13

ATF – A Smart Journey for your Digital Enterprise
We hope to see you at one of these great events!

Follow me on Twitter @Fletch911
Read my other AVAYA CONNECTED Blogs


Mark J. Fletcher, ENP is the Chief Architect for Worldwide Public Safety Solutions at Avaya. As a seasoned professional with nearly 30 years of service, he directs the strategic roadmap for Next Generation Emergency Services in both the Enterprise and Government portfolios at Avaya. In 2014, Fletcher was made a member of the NENA Institute Board in the US, in 2014 – 2015 he served as co-chair of the EENA NG112 Committee in the European Union, providing valuable insight to State and Federal legislators globally driving forward both innovation and compliance.

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