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For businesses operating Multi-Line Telephone Systems (MLTS), ensuring that emergency calls to 911 are directed quickly and accurately is not just a safety measure—it’s now a federally mandated requirement under 47 CFR §9.3 in the United States Code of Federal Regulations. Enforcement is controlled by the Department of Justice, and the potential cost of a solution pales in comparison to the potential fines and penalties.
Obtaining the Right Resources
Since testing these systems in a corporate environment is crucial, it must be done responsibly and pre-planned to avoid any unnecessary burdens on emergency services. I’ll provide some general industry-accepted best practices in this blog. However, you are highly urged to enlist the services of a knowledgeable consultant and even a NENA-certified Emergency Number Professional (ENP). These folks can advise and assist with the most appropriate design and setup for your particular environment and your communications platform(s). Having this technical expertise on hand to recommend a plan to properly test 911 calling from YOUR MLTS setup, including an explanation of the 933 address verification services offered by many carriers, could end up saving both time and effort in achieving compliance.
Understanding MLTS and Its Importance
MLTS are used in hotels, campuses, and large office buildings, allowing them to manage internal and external communications across multiple phone lines. Regarding emergency calls, however, these systems can introduce additional management complexities that might delay updating the information with local 911 services. Ensuring that these systems efficiency provide the exact location and appropriate call-back information for emergency operators is essential for the safety of everyone in the building. The Society of Communications and Technology Consultants (SCTC), has several members now well versed in this space, and access to various technical resources are available for projects of varying complexity. (http://sctcconsultants.org).
Legal Requirements
Legislation is now applicable federally. Recent laws, such as Kari’s Law and the RAY BAUM’s Act in the United States, now mandate direct dialing, contemporaneous notification internally and to the 911 PSAP, and outline requirements for dispatchable location reporting by businesses using an MLTS. These laws were enacted specifically to enhance the effectiveness of emergency calling and responses in an Enterprise environment. Becoming compliant is one thing, but as infrastructure changes occur in any business, remaining compliant with these laws requires regular testing and assurance that the MLTS performs as required.
Step-by-Step Guide to Testing 911 in MLTS
NOTE: These are general best practices. Each 911 deployment environment can be different, and some jurisdictions may impose special policies and procedures on implementation and testing. This is where money spent on a consultant that specializes in 911 deployments and a NENA certified Emergency Number Professional are well worth the investment in time and effort.
1. Planning Your Test
• Develop a Plan: Prior to the commencement of any testing, an established plan must be defined. This plan must define a minimum level of compliance that is not only tested but also measurable.
• Internal Audit: Since testing can often be disruptive and consume resources internally and at the 911 center, it is a good practice to perform a manual “stare and compare” audit on the database to locate any anomalies that can be corrected prior to the test event. Performing these tasks ahead of time can actually save on more expensive resources on the backend.
• Schedule: Proper coordination with the relevant stakeholders, such as your MLTS provider and local emergency authorities, is required prior to initiating any test event. This ensures that all interested parties know about the test event and can differentiate it from a real emergency.
• Notification: Socialize and inform all internal stakeholders about the test to prevent panic or misinformation about any emergency situation, being simulated from being real.
2. Using the 933 Test Call Service
• What is 933? Today, many specialized 911 carriers offer a 933-calling service specifically for testing 911 functionality without having to place an actual emergency call. Dialing 933 from an MLTS-connected phone connects the caller to an automated service that looks something 911 record in the database, and then uses an IVR to read back the phone number and address registered with the system. This is useful in simulating and verifying the accuracy of the “dispatchable location” information that would be sent to emergency services.
• Benefits: Using 933 helps confirm that your system is properly configured to provide the precise location information necessary for emergency services to respond effectively. It also provides a mechanism to ensure the system is compliant and configured correctly before the actual physical test to 911.
3. Conducting the Test
• Follow Procedures: Make certain 933 is provisioned properly as per the instructions from your MLTS provider. 933 should have IDENTICAL ROUTING to the 911 service provider as normal 911 calls. Follow their procedure and that of your MLTS.
• Visual Verification of Information: Examine the MLTS provisioning and database looking for obvious errors. This will help ensure the system is correct as possible BEFORE making any test calls.
• Physically Verify Information: Dial 933 from each device, checking that the read-back information accurately reflects the intended location and calling line identity. Any discrepancies must be addressed immediately with your MLTS provider. Performing these tasks, allow you to identify and correct any incorrect database entries, or programming misconfiguration in the MLTS.
4. Evaluate and Adjust
• Assess Performance: Evaluate the test results to determine if the MLTS meets direct dialing and location accuracy requirements.
• Make Adjustments: Work with your MLTS and 911 Service providers, making any necessary adjustments to the system configuration.
5. Documentation and Compliance
• Record Keeping: Keep detailed records of each test, including the date, time, the specific lines tested, and the results. This documentation will be crucial for compliance audits and future troubleshooting. It is also your proof that your system was compliant and that you took the necessary steps to ensure that in the event of a lawsuit in the future.
• Regular Reviews: Schedule regular reviews and tests of your MLTS to ensure ongoing compliance and to account for any changes in your office layout or system updates. Remember, 933 testing can be done anytime, and by anyone. During large MAC events, or changes, it is a simple task for a technician or administrative person to place 933 calls from devices that were moved. This will ensure that a level of compliance was maintained.
Testing your corporate MLTS for 911 calling is now critical to your organization’s overall emergency preparedness strategy. By utilizing the 933-test call feature, businesses can ensure their systems are compliant and functional without unnecessarily engaging actual emergency services. This process not only aids in compliance with safety regulations but also reinforces your commitment to the safety and well-being of everyone in your facility. Regular testing and updates are necessary to keep pace with technological and regulatory changes, ensuring your emergency response capabilities remain effective and reliable. The scheduling of these audits will be directly related to the number of changes that occur within the network and the nomad behavior of the workforce.
When designing a brand new 911 response plan or reviewing the effectiveness of an existing plan, make sure you engage the appropriate individuals for their input. Obviously, representation from IT and telecom are mandatory but don’t forget about involving human resources, as well as corporate legal, for their input. Keep in mind that you’re not implementing a 911 solution in the enterprise to check a box on a checklist; you’re implementing critical infrastructure and functionality that can directly impact personal life safety for employees in your company.
Finally, managing this infrastructure can be challenging without the appropriate tools and network forensic utilities to track device and user location. NG 911 significantly changes what enterprises can send, specifically the level of detail. For a fully functional NG 911 solution built from the ground up to address this situation with NG 911 technology, visit www.911inform.com, or call 833-333-1911 to speak with a solutions expert.
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