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Compliance

Kari’s Law

PURPOSE

 
An act to amend the Communications Act of 1934 to require multi-line telephone systems to have a configuration that permits users to directly initiate a call to 9-1-1 without dialing any additional digit, code, prefix, or post-fix, and for other purposes.

HISTORY

 
The law is named in honor of Kari Hunt, who was killed in a motel room by her estranged husband in 2013. Her daughter tried to call 911 four times, but the calls never went through because the motel’s phone system required dialing “9” before any call to secure an outbound phone line.

Under the statute, which went into effect on February 16, 2020, MLTS vendors and manufacturers must configure new systems to support direct dialing 911. The system must also send a notification to a central location on- or off-site, such as a front desk or security kiosk. The notification will provide an alert that a 911 call was placed and include a callback number and information about the caller’s location.

APPLICABILITY TO BYUH

 
Every enterprise with a multi-line telephone (MLTS) system purchased, installed or significantly upgraded after February 16, 2020, is required to comply with the FCC Rules pertaining to Kari’s Law. As of right now this does not apply to BYU–Hawaii as our system is older than 2020 and has not been significantly upgraded.

REQUIREMENTS

 
Kari’s Law requires businesses to enable the direct dialing of “911” and directs the FCC to establish necessary 911 calling regulations for the MLTS that are commonly used in buildings on campus.

The Two Requirements of Kari’s Law: Direct Dialing and Notification

Direct Dialing Requirements

Accessibility to 9-1-1 services translates into the “Direct Dialing” component of Kari’s Law. Direct Dialing simply means that your enterprise communications system must enable direct dial to 9-1-1 without the addition of a prefix. If someone picks up the phone and dials 9-1-1, they must be connected to an emergency dispatcher, regardless of if the device is a traditional phone or VoIP system such as Cisco Webex or Microsoft Teams.

Here’s a simple rule to follow: If you can dial for pizza from your device, then you must be able to directly dial 9-1-1.

While this capability is typically the responsibility of the manufacturer, organizations must verify the communication systems they use are configured in such a way as to allow direct dialing.

Notification Requirement

Kari’s Law states that your system must automatically notify the front desk, security office, or administrative personnel for every 9-1-1 call within your network.

Additionally, the notification needs to provide specific information about the call, including the phone number that dialed 9-1-1, and the location of where the call was placed. This information must match the location data that is sent to the 9-1-1 call taker (usually a Public Safety Answering Point – PSAP).

The location of the caller is absolutely critical for these notifications to work. A simple street address without the location detail of the 9-1-1 call is rendered useless when the emergency takes place in a multi-floor building, large campus environment, warehouse, etc. This means that your communication system needs to provide notifications of a 9-1-1 call, as well as pinpoint the location of where the call is coming from within your enterprise. Furthermore, it is in an organization’s best interest for the location provided in this notification to be as detailed as possible. This allows organizations to proactively comply with the RAY BAUM Act, which requires organizations to provide what the FCC is calling “dispatchable locations” to emergency dispatchers for any emergency caller.

PENALTIES

 
Any business found in non-compliance with the mandates set by Kari’s Law could face a fine of up to $10,000 plus $500/day for the period of non-compliance.

In addition to other penalties and fines set by the FCC, your organization could be exposed to civil litigation based on failure to protect individuals using your phone systems. Furthermore, increasing numbers of organizations are outlining duty of care responsibilities to employees. Complying with Kari’s Law demonstrates your business is following best practices around access to emergency services during a critical event.