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E911 - Important Information

Introduction

The requirement for understanding E911 and everything related to it is a frequent topic brought up by dealers and MSPs, especially those new to telephony and VoIP. Because this is a critical issue for anyone responsible for telephony systems, we want to help you understand how it works when you partner with SIPTRUNK. This article contains important information for laws which require compliance, key terms, how to set up and test configurations, operating processes, and most importantly, how to help save lives. 

 

Ray Baum's Act

Ray Baum's Act, specifically section 506, mandates that any multi-line telephone system (MLTS) used by telecom companies or VoIP service providers, like SIPTRUNK, must be capable of providing 911 dispatch for any location in the United States. SIPTRUNK requires public-safety answering point (PSAP) information when associating an Enhanced 911 (E911) address to a telephone number (TN). When using the SIPTRUNK E911 product, customers provide the necessary identifiable information for emergency dispatch services.

 

The Act has expanded the scope of VoIP providers required to offer E911 services. To comply with this, SIPTRUNK charges a monthly service fee which covers legal and regulatory charges, including increases to state and local taxes on E911 services.

 

Kari's Law

Kari's Law is a subsection that was later added into Ray Baum's Act, which states that anyone must be able to reach a 911 call center when directly dialing 911 from an MLTS. The goals of Ray Baum's Act and Kari's Law are to ensure standardization and reliability for any calls made from an MLTS or VoIP provider service, like the service SIPTRUNK provides, in order to precisely locate a 911 caller. The location information that's passed is essential in high-rise buildings and multi-floored locations that may employ VoIP PBX systems. SIPTRUNK provides SIP service, enabling a PBX to work as a company telephone system. Under this act, the process of dialing 911 must be directly accessible without any pre-dial.

 

Contextually, the incident behind Kari's Law was due to an inability to dial 911 effectively and predictably. The incident led to a death because the caller was unfamiliar with a motel's pre-dial requirement to dial "9" before dialing "911" in order to call out to emergency services. Now, MLTS and VoIP service providers in the United States must connect to 911 without any additional dialing requirement.

 

Example: A SIPTRUNK user wishes to dial the SIPTRUNK main support phone number: 8002506510. In the following example, "9" could be the pre-dial (if the phone system was configured to require a pre-dial), signaling you want to reach an external destination. Since SIPTRUNK requires an 11-digit format for outbound North American calls, the "1" would need to be manually dialed or programmed into the dialing pattern: (9)(1) 800-250-6510.

 

This demonstrates the potential for custom requirements to confuse users and impede emergency communication. This is why phone systems and providers MUST allow end users to simply dial "911" and be connected with emergency services, along with the phone system transmitting a corresponding caller ID that provides exact location information for the PSAP to respond to for that call, and a direct telephone number to call the requester back if necessary.

 

IMPORTANT: Responsibility is ultimately up to the MSP or whoever manages the phone system to cite local requirements for compliance with Ray Baum's Act and Kari's Law. For example, some states require you to have an Enhanced DID for each room/suite in a building, or for each building on a campus, etc. Refer to the following compliance resources for exact information. 

 

Compliance Resources

The following government resources will assist you in achieving compliance with everything E911-related when configuring a MLTS VoIP system:

Key Terms

  • Standard DID - The lowest cost DID at SIPTRUNK where NO address information is input into our system.

  • Enhanced DID - An upgraded DID at SIPTRUNK where address information is input into our system which can be forwarded to a PSAP.

  • Public Safety Answering Point (PSAP) - Public safety telecommunicators are the responders for emergency situations when someone dials 911. The role of the PSAP is to obtain essential information and send the appropriate responders to the right location. These are often referred to interchangeably as Emergency Contact Centers (ECC). 

  • Multi-line Telephone System (MLTS) - An enterprise/professional-grade phone system that offers a wide range of control and configuration options including scalability for a large number of users with assignable privileges and definable users. Common deployment of MLTS includes high-rises, campuses, compounds, and other large facilities. An MLTS may also be used to facilitate communication across multiple sites within an organization. These are often referred to interchangeably as PBXs, ATAs, etc. 
  • Outbound Caller ID - The telephone number transmitted as the FROM number in an outbound call. This is the same as the FROM header in the SIP INVITE. This is the number a PSAP can call back in the event of an emergency in which additional communication is required from the party requesting emergency services. 

  • Pre-dial - Refers to a custom requirement of a phone system to dial a specific number string before entering a destination number in the standard NXX or NPANXXXXXX format.

Key Points

  • Per 911.gov: "RAY BAUM’S Act emphasizes the importance of making dispatchable location information from all 911 calls available to PSAPs, regardless of the technological platform used. The FCC states “dispatchable location means a location delivered to the public safety answering point (PSAP) with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment or similar information.”
  • Per the FCC: A user must be able to directly dial 911 without delay and "without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for the other calls. (47 CFR § 9.16(a)(1))."

  • Per the FCC: "When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification shall include, at a minimum, the following information:

    1. The fact that a 911 call has been made;

    2. A valid callback number; and

    3. The information about the caller's location that the MLTS conveys to the public safety answering point (PSAP) with the call to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information. (47 CFR § 9.3.)"

  • Per the FCC, the caller ID must be configured so that when transmitted by the calling party requesting E911 emergency services, it provides a direct callback point to the calling party in the event the PSAP or emergency responders need to request/communicate additional information.

  • When a user dials 911 with the caller ID associated with an Enhanced DID, a lookup is done for the address on file and the call is sent to the 911 PSAP.

  • Standard DID numbers are not meant for 911 calls. If a user dials 911 via SIPTRUNK, and the caller ID is NOT an Enhanced DID in our system, the call will route to a generic 911 call center where they will attempt to get the caller's location and then forward the call to the nearest PSAP. SIPTRUNK is also assessed a $75 charge for dialing 911 using a non-provisioned caller ID number by its carrier. SIPTRUNK passes this $75 charge on to its customers.

  • There are no additional surcharges or penalties when dialing to 911 when the calling party uses a caller ID of an Enhanced DID.

  • Many customers buy at least 1 Enhanced DID and set the address for that DID (which can be changed at any time). They then use that number as the outbound caller ID number for outbound dialing to 911. However, the managing party for the phone system must check local laws for exact compliance. SIPTRUNK does not provide legal advice on how to configure your MLTS/PBX. 

How to Get an Enhanced DID and Configuration

SIPTRUNK allows you to purchase a new DID and provision it as Enhanced or you can convert Standard DIDs to Enhanced DIDs. Follow these guides for the full processes:

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    Felicia King

    Thanks for the fantastic article. This is exactly what I needed.

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