Kari's Law and Ray Baum's Act Compliance
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.
This advice is provided in hopes that it will be useful in guiding your conversation with an attorney or legal advisor who can make recommendations based on your specific situation. It is not intended to provide legal advisement as it makes broad assumptions that may or may not apply to your specific circumstances.
Any information provided here regarding "Asterisk" or "FreePBX" servers refers only to Telos-commissioned FreePBX (Asterisk) servers used with Telos Alliance telephony products. While these are third-party servers and software, we are able to provide limited pointers and advice (like this article) under normal support.
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 only applies to MLTS (multi-line telephone systems). The FCC has indicated that a "MLTS refers to a system and that 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 itself is not an MLTS until is is connected to a PBX system providing access to the PSTN (public switched telephone network). The VX is simply a collection of endpoints, just like a VoIP desk phone.
However, when connected to and as a component of such a system, the VX does allow dialing of 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 passes 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 itself transmit E911 location data. It is only able to 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 both Kari's Law and Ray Baum's Act if required.
As this is advanced configuration and is 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.