Legal Alerts Oct 31, 2019

Reminder: New Federal 911 Law Goes Into Effect in February

Kari’s Law Sets New Requirements for Multi-Line Telephone Systems

“Kari’s Law” imposes 911 direct dialing requirements on multi-line telephone systems, and those requirements are going into effect in February. Most public agencies and many businesses will be impacted by Kari’s Law, as MLTS are frequently used in office buildings, hospitals, schools, government agencies and hotels.
In a previous Legal Alert published in February 2018, right after Kari’s Law passed, we detailed how the new law requires most MLTS to be pre-configured so users may dial 911 without having to dial any sort of prefix. MLTS must also be capable of sending alerts to a designated central point of contact when 911 is dialed on the system. Kari’s Law imposes these requirements on manufacturers, importers, sellers, lessors and those engaged in the business of installing, managing or operating MLTS — but it did provide a 2-year grace period for these groups to comply. That grace period is coming to an end Feb. 16.
Any public agency or business that controls or is otherwise responsible for configuring its MLTS should assume it is the “operator” or “manager,” and therefore responsible for complying with Kari’s Law. Kari’s Law defines an MLTS as 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. The statute specifies that the definition includes systems owned or leased by governmental agencies and nonprofit entities, as well as for profit businesses.
Specifically, Kari’s Law mandates that MLTS are preconfigured such that a user may dial 911 without first dialing any additional digit, code, prefix or post-fix, even if the MLTS otherwise requires it for other calls outside its system. The installment, management and operation of MLTS lacking this capability is prohibited, as is their manufacture, importation, sale and lease. In addition, MLTS must be configured to provide a notification whenever 911 is dialed from the system to a central location at the facility where the MLTS is installed, or to a different location of the system operator’s choosing. This last requirement will only apply, however, if the system can be configured to provide the notification without an improvement to the hardware or software of the system.
Since Kari’s Law was initially passed, the Federal Communications Commission passed rules to implement the legislation. The FCC clarified that Kari’s Law applies to both legacy MLTS and Internet Protocol-based systems, including cloud-based services, that support the communications needs of hotels, businesses, campuses and other enterprises. The FCC also provided specific contents for the notifications that MLTS must provide, clarifying that they should include the fact that a 911 call was made, a valid callback number, and the same location information that is conveyed with the call to 911. However, there is an exception for callback number and location information in circumstances where including this information would not be technically feasible. The FCC’s regulations will also go into effect on Feb. 16.
For more assistance in determining whether an MLTS is compliant with Kari’s Law and the FCC’s associated regulations, please contact the authors of this Legal Alert to the right in the firm’s Telecommunications practice group, or your BB&K attorney.
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Disclaimer: BB&K Legal Alerts are not intended as legal advice. Additional facts or future developments may affect subjects contained herein. Seek the advice of an attorney before acting or relying upon any information in this communiqué.  

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