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January 2022 deadline for 911 calling laws: Are your phones compliant?

January 6, 2022

Congress passed Kari’s Law in honor of Kari Hunt, who was killed by her estranged husband in a hotel room in 2013. Kari’s 9-year-old daughter tried to call 911 four times from the hotel room, but her calls did not go through because she did not know to dial 9 before dialing 911. Together, with the RAY BAUM Act, Kari’s Law makes it easier for people to contact 911 emergency services and for first responders to locate and help people, by requiring covered business to update their phone systems so that a caller does not have to dial a prefix (meaning another number or symbol) before dialing 911, among other updates (as further explained below).

Jan. 6, 2022, marks the final compliance deadline for a series of requirements under Kari's Law and the RAY BAUM Act and their implementing regulations (collectively, the Act).

What businesses are covered?

The Act’s requirements apply to “a person engaged in the business of installing, managing or operating multi-line telephone systems” and any multi-line telephone system that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed after Feb. 16, 2020.

A multi-line telephone system is defined as “a system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises-based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems…and includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.” Stated another way, it is a phone or other calling system with more than one line. The Act’s regulations apply to traditional multi-line telephones, as well as Voice over Internet Protocol (VoIP) and cloud-based systems like Microsoft Teams, Zoom, Nextiva, Vonage, Dialpad and more.

Practically, this means that businesses that use multi-line phone systems, whether they are landlines, VoIP or in the cloud, that were installed on or after Feb. 16, 2020, are covered. As a result, most large enterprises, and many small- to mid-size businesses, may be covered. Many employers converted to VoIP and cloud-based systems during the pandemic.

What are a business’ obligations? 

Several requirements under the Act are already in place:

  • By Feb. 16, 2020, companies were required to:
  1. Configure their multi-line phone systems to allow for direct 911 dialing (i.e., dialing 911 without a prefix, such as the #9)
  2. Send a notification of a 911 call to a central company location like a front desk or security office
  • By Jan. 6, 2021, companies were required to configure their on-premises, fixed telephone (e.g., a wired desk phone) associated with a multi-line telephone system to send an automated “dispatchable location” to dispatch centers when a 911 call is made. A “dispatchable location” means a validated street address for the person making the call, as well as information that helps to identify where the call is from, such as suite or apartment number, or similar information necessary to adequately identify the location of the calling party.

By Jan. 6, 2022, an on-premises, non-fixed device (e.g., a cordless office phone) or an off-premises device (e.g., devices used by remote workers) associated with a multi-line telephone system must provide an automated dispatchable location, when technically feasible, or meet an alternative outlined in the regulations.

What are the legal risks?

Failure to comply with these requirements may result in fines of up to $10,000 per violation and $500 per day the company is in noncompliance. Employers should work with internal information technology personnel and external consultants to comply with these requirements as soon as possible.

How to learn more

Businesses may refer to the Federal Communications Commission’s guidance for more information, including the language of the regulations, FAQ documents and compliance guidance for small entities.

For more information on this topic, or to learn how Godfrey & Kahn can help, contact a member of our Labor, Employment & Immigration Law Practice Group.

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