Kari’s Law – Countdown to Compliance

At the time I’m writing this, 477 days have passed since I stood in the Oval Office along with Hank Hunt as we witnessed Kari’s Law becoming the law of the land. While not strongly worded as such, the intent of the law was that, from that day forward, an MLTS phone system installed or put into service would be compliant with direct access to 911 without an access code, any calls to 911 would route directly to the PSAP and not be intercepted internally, and unless an upgrade was required, the system would provide some mechanism of notification that an emergency call took place.

Any existing MLTS systems that were installed prior to that date would have a two-year grace period in which to make their system compliant, with February 16, 2020 as the final date when legislatively this would be required. While system administrators and vendors have had almost 16 months to deal with the issue, many still have not. Now, with the deadline approaching quickly, the mad rush is on to secure system capabilities, and provide safe work environments for employees and guests.

Last year at the Avaya ENGAGE Event, Hank Hunt (Kari’s Dad) graciously sat down and recorded this video message:

Hank Hunt on Kari’s Law

Just a little more than a month after Kari’s Law was signed, the president signed Ray Baum’s Act, named in honor of a popular political figure that had recently passed away. The primary purpose of this act was to reauthorize the Federal Communications Commission and establish its operating budget.

With this act being a ”must pass” piece of legislation, it is popular for many other bills that will not stand on their own to become attached to it. One of those pieces of legislation is known as section 506 of the Ray Baum’s Act, and it has recently caused a bit of a stir in the MLTS community.

In this legislation, it establishes a requirement that the FCC conclude a proceeding within 18 months examining it further requirements are needed for location reporting on multi line telephone systems. The due date for that proceeding conclusion is September 23 of this year. This section calls off the need for a dispatchable location to be provided to public safety answer points when and MLTS initiates a 911 call. BUT, as I’ve said many times before, the most critical piece of any law is the definition of specific terms, and the same is applicable here.

In the Act, a dispatchable location is defined as one that, “means 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”.

Unfortunately, this is being hyped as requiring the exact room or cube number of the caller being delivered directly to the PSAP, when in fact that information is completely irrelevant without additional context. The fact that I sit in cube 2C-231, has no meaning to anyone outside of my company.

1st responders don’t know where 2C-231 is within the building, or even what floor it is on, so it has little relevance. It is very relevant, to internal first responders within the facility, and it could be provided to public safety first responders on an electronic display, and now with context, like a floor plan. This can now be provided directly with the 911 call itself, thanks to new over-the-top NG 911 technology provided by the Rapid SOS NG911 Clearinghouse.

Screen Pop information made available to internal 1st responders and now deliverable to PSAPs via the RapidSOS NG911 Clearinghouse
Additional Context Available in the Enterprise

In the past, establishing 911 database records for every station within the facility created two problems. The first, was that every single device needed a unique and dialable public telephone number in order to identify itself, and secondly a unique record for each device needed to exist in the 911 ANI/ALI database, which incurred a significant monthly recurring cost. While at the surface, this seems to be useful information, it actually creates a false sense of security, as well as an administrative management nightmare, while providing minimal useful information. This is because in legacy solutions, the ability to pass additional context such as a floorplan is next to impossible.

Is this too much work, with no time to complete it?

Depending on the size and complexity of the enterprise, the 911 plan can be quick and simple to implement, or it may become a long drawn out process. This is where a waiver can help tremendously providing some additional time, where warranted. One of the initial states to adopt legislation was the State of Texas, Kari’s home State. During various hearings that took place in Austin, I suggested that waivers be granted to those that specifically apply for them, and as part of the application, the MLTS make and model number, as well as its software release be put on file, as well as evidence that a good faith effort was made to purchase a new system.

This simple clause solved a couple of primary issues. First and foremost, it forced businesses to make an effort and investigate what their situation was, and secondly it created a list of compliant MLTS systems, and release levels, which prevented unscrupulous distributors from up selling the general public when it wasn’t warranted. The waivers were good for one year, and needed to be renewed each September.

Since 2016 when the law went into place, the number of waivers filed each year has dropped by 20%, as more and more noncompliant systems were replaced with those that were compliant. As the graph below shows, in 2016, the very first year, 630 wavers we’re granted. In 2017, that number dropped significantly to 386, and in 2018 it was further reduced to only 252. Those systems granted a waiver also needed to make sure that users of their system we’re well aware of how to dial 911, with very specific placard requirements. Obviously, any new system purchased what have to be compliant upon installation.

MLTS Waivers Issued (and projected) by Texas CSEC 2016 – 2020

911 is the most critical call you may ever have to make. As manufacturers of systems globally, we make sure that our users are well aware of this problem, and that’s why we stood behind Hank Hunt’s initiative on Kari’s Law from the very beginning.

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