Your multi-line phone system and federal rules about 911 calls: What you need to know

When someone’s heart is pounding in an emergency, hopefully that person can remember to dial 911. With today’s Enhanced 911 (E911) technology, often merely placing the call means emergency responders can identify where the caller is located, enabling help to arrive on-site with little additional information from the caller. This can be a life-saving tool. With all the changes in communications technology, however, how can we be sure that the right location information is transmitted? Today we are using cloud-based integrated calling and email, VPNs, apps on mobile phones and more. Will first responders be able to find the caller when 911 is dialed?

Congress and the Federal Communications Commission (FCC) have adopted laws and rules to address this concern in the last few years. Recent changes in federal rules apply to any multi-line phone system—whether it is a physical system or whether it virtual or in the cloud—bought, leased or installed after February 2020. These new rules are particularly relevant since many entities are installing or considering new communications systems to meet new workplace needs brought on by the COVID-19 pandemic.

The federal rules are intended to ensure that members of the public can successfully dial 911 to request emergency services and that first responders can quickly and accurately locate every 911 caller, regardless of the type of service that is used to make the call. Depending on the capabilities of your system, now and in the future, multi-line telephone system (MLTS) operators have obligations to provide location information along with a 911 call and must automatically initiate a central notification within their own organizations. Ensuring that employees and others who use our facilities can get help during an emergency is a best practice to safeguard our most important assets—your people.

Here are the basics:

1. No prefix. A multi-line telephone system must be pre-configured and operated so that a user may directly call 911 without having to dial a prefix, such as an additional digit or code (such as the digit 9).
2. Central location notification. If the multi-line telephone system can do so without an improvement to the hardware or software of the system, a MLTS must provide, for each 911 call, a notification to a central location at the facility where the system is installed or to another person or organization regardless of location. The notification must include: (a) that a 911 call has been made; (b) a valid callback number (if it is technically feasible); and (c) the information about the caller’s location that the MLTS conveys with the call to 911.According to the FCC’s guidance, the central notification should go to whomever “has the keys” if a campus or building has restricted access and to staff that might best assist public safety in locating and responding to a 911 call. This rule applies even where devices used as part of the MLTS are located at satellite locations, off-site, remote, on the road or at-home locations.

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