Kari's Law and Ray Baum's Act Compliance
Updated
by
Bryan Jones
Scope
This article addresses compliance with Kari's Law and Section 506 of Ray Baum's Act from the perspective of an Asterisk PBX and/or Telos talk show system such as the VX.
What is Kari's Law?
"Kari’s Law applies to multi-line telephone systems (MLTS), which are telephone systems often used by office buildings, campuses, and hotels. Kari’s Law requires MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020, to enable users to dial 911 directly, without having to dial a prefix to reach an outside line and to provide for notification (e.g., to a front desk or security office) when a 911 call is made" (34 FCC Rcd 6607 (8)).
What is Section 506 of Ray Baum's Act?
Ray Baum's act requires "that a 'dispatch-able location' is conveyed with 911 calls, regardless of the technological platform used, so that 911 call centers will receive the caller’s location automatically and can dispatch responders more quickly" (34 FCC Rcd 6607 (8)).
How does this affect my VX?
Kari's Law
Kari's Law only applies to MLTS (multi-line telephone systems). The FCC has indicated that a "MLTS refers to a system and the individual components of such a system, including telephone sets, control software and hardware, and adjunct systems, do not by themselves constitute an MLTS" (FCC-CIRC1908-05, pg. 23).
The VX is not an MLTS until it is connected to a PBX system providing access to the PSTN (public switched telephone network). The VX is a collection of endpoints, like a VoIP desk phone.
However, when connected to and as a component of such a system, the VX does allow dialing 911 without a prefix or postfix (or any number for that matter, as it directly passes the dialed number to the PBX).
As the VX is only an endpoint, it cannot provide notification to a central location when 911 is dialed. This must be handled by the PBX the VX is connected to.
In this way, the VX can comply with Kari's Law when connected to a compliant PBX.
Ray Baum's Act
The requirement to convey a "dispatchable location" with 911 calls is not directly a function of the VX or PBX it connects to. The VX and/or PBX pass along a Caller ID (CID) number with each outbound call. The PSTN access provider (could be a local provider such as Comcast or a hosted provider such as Vonage) maps that call to an E911 address. The mapping typically occurs either:
- On a per-trunk basis
- All calls from the PBX/trunk, regardless of CID transmitted, are mapped to the same E911 address.
- This is simplest as it does not require the customer to map each CID number to a specific address, floor, or room number.
- However, it does mean that the location information transmitted is not granular to the specific floor or studio the call was placed from.
- On a per-CID basis
- Each CID number is individually mapped to a specific E911 location, for example, a specific studio or floor in the building.
- This is more complex as it requires the customer to map each CID number to a specific address, floor, or room number.
- However, it does mean that the location information transmitted can be very granular to the specific floor or studio the call was placed from.
Regardless of the method chosen, this process requires coordination between the PBX operator and the PSTN access provider. The VX, or even a PBX, cannot transmit E911 location data. It can obly transmit a CID number, which the PSTN provider must map to an E911 location.
In this way, the VX can comply with Ray Baum's Act when connected to a compliant PBX and compliant PSTN provider.
How does this affect my FreePBX (Asterisk) server or other PBX?
Telos Alliance is equipped to configure Telos-commissioned FreePBX (Asterisk) servers to comply with Kari's Law and Ray Baum's Act if required.
As this is an advanced configuration tailored specifically to each situation, we provide this assistance through various paid TelosCare Service Level Agreement options or a la carte via our Dedicated Remote and Onsite Support service. Please use the Contact Us link above for more information on these options.
