Many employers have multi-line phone systems at the workplace. Most employers have emergency action plans and evacuation procedures. The connection between those matters may not be readily apparent, but if employees cannot directly dial 911 from company lines, emergency procedures are incomplete. Complicating the issue is the fact that many offices have different floors, different buildings on a campus, different sections per floor, and sometimes different addresses. To be effective, a 911 call must convey the precise location of the emergency.
Federal and state governments have a vested interest in improving the effectiveness and reliability of 911 calls. We’ve seen progress in Federal Communication Commission (FCC) rules for wireless Enhanced 911 (E911) that require carriers to implement upgrades that route 911 calls based on the location of the call and provide more accurate location of the call origin.
Of equal importance to the FCC, albeit less publicized, is enhancing 911 calling from multi-line telephone systems. February 2018 marked the 50thanniversary of the first 911 call, and the President signed two new laws that day to improve emergency calling:
- The first, Kari’s Law, was named for a Texas woman who died from stab wounds in a hotel room. Her 9-year-old daughter repeatedly dialed 911 but did not reach emergency responders because she didn’t understand the requirement to dial “9” first to reach an outside line. The law requires multi-line telephone systems to have a default configuration that enables users to call 911 without a prefix. The systems also must provide notification of the 911 call to a central desk or security office in order to facilitate entry to the building by first responders.
- The RAY BAUM Act, named in honor of the late Energy & Commerce staff director, requires the FCC to consider rules that ensure that location information — street address, floor level, and room number of a 911 caller — is sent with a 911 call, regardless of technological platform. The requirements include multi-line telephone systems, interconnected VoIP, and other platforms.
While the FCC develops rules around these regulations, twenty states currently have enacted enhanced 911 legislation that requires businesses to provide 911 protection. The National Conference of State Legislatures maintains a database of 911 legislation for each state. In Texas, for example, business owners using VoIP service must allow direct access of 911 without an additional code, prefix, postfix, or truck access code, and must provide notification of the call to a central location. Texas enacts 911 legislation by county, and each has a 911 or emergency coordinator that maintains specific 911 requirements for the county.
Changes in regulatory requirements combined with advancements in technology that affects 911 call delivery make this a complicated issue. Employers should take steps to develop a plan to fulfill state and federal 911 requirements, but first must understand the exact requirements. Doing so will likely mean consultation on technological solutions as well as legal compliance. As is the case with all labor and employment law, the bottom line is finding answers that provide a safe work environment for employees while limiting liability for employers. We are happy to advise you on the best approach for your business.