Is Your Business Ready for Kari's Law?

New multiline phone systems must allow direct dialing to 911 and notify designated staff

Lisa Nagele-Piazza, J.D., SHRM-SCP By Lisa Nagele-Piazza, J.D., SHRM-SCP February 10, 2020
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​Companies that use multiline telephone systems (MLTSs) installed or manufactured after Feb. 16—the 52nd anniversary of the first 911 call made in the U.S.—must comply with a new regulation for calls made to emergency services.Although the compliance date is rapidly approaching, there's still confusion over what's required, said Tricia McConnell, product marketing manager for 911 with communications platform Bandwidth Inc."This has really flown under the radar," said Alec Beck, an attorney with Barnes & Thornburg in Minneapolis, "but it's a big deal in terms of compliance."

MLTSs are commonly used in office buildings and hospitals, on school campuses, and in hotels and usually require people to dial a prefix, such as a 9, before making an external call. Kari's Law mandates that these phone systems allow direct dialing to 911 and notify designated staff when emergency services have been contacted. 

"In particular, these rules will make it easier for Americans in hotels, office buildings and campuses to dial 911 and reach the help that they need in an emergency," said Ajit Pai, chairman of the Federal Communications Commission (FCC). "And they will make it more likely that when such a 911 call is placed, an onsite notification is provided so that an employee can help speed response times when emergency personnel arrives."

The Details

Kari's Law applies to any "person engaged in the business of manufacturing, importing, selling or leasing" MLTSs and any "person engaged in the business of installing, managing or operating" MLTSs. Though it applies only to MLTSs installed or manufactured after Feb. 16, Pai suggests that businesses with older multiline systems call the company that maintains them and request a change to direct access.

In addition to standard phones, "soft" phones that make calls over the Internet are covered, too. Under a final rule issued in December 2019, the FCC said it interprets the definition of MLTS "to include the full range of networked communications systems that serve enterprises, including circuit-switched and IP-based enterprise systems, as well as cloud-based IP technology and over-the-top applications." 

Tragedy Prompts Law

"Most of us assume if there's a phone, we can call 911," McConnell said. But that's not always the case.

The new regulation stems from heartbreaking circumstances. Hank Hunt's daughter, Kari Hunt Dunn, was attacked and killed by her estranged husband in a hotel room. Dunn's 9-year-old daughter tried to call 911 from the room, but her calls never went through because the hotel's phone system required guests to dial a 9 before placing outside calls.

Hunt lobbied for several years for the FCC to require direct dialing to 911, and ultimately Kari's Law was signed. "What began with one man in East Texas soon became a nationwide movement," Pai said. "And that nationwide movement eventually led to congressional action."

Compliance Tips

Complying with Kari's Law shouldn't be too difficult, Beck said, but people have to know about the law and follow through with the updates. "HR and IT need to make sure they are up to speed and that everyone knows about it," he said.

McConnell noted that HR professionals tend to be the champions of employee safety and can raise awareness. "Get with the legal decision-maker and the IT decision-maker," she said. Figure out who in the organization will get notified when there's a 911 call and what procedures should be in place for remote workers, she added.

[SHRM members-only online discussion platform: SHRM Connect]

Beck said employers will need to provide some training. "There needs to be a centralized location or person to get the notice, and that's the place to start." Make sure the phone systems are updated with the right software and that everyone is aware of the changes and the process, he added.

"Test the process," McConnell said. "Make sure it works." She noted that there are ways to test the system without disrupting public safety.

Businesses should also note that state laws sometimes exceed what federal law requires. "Meet the highest standard for all locations," McConnell recommended.

More to Come

Another law on calling emergency services is slated to take effect for some phone types in January 2021. Among other requirements, RAY BAUM's Act will mandate that a "dispatchable location" is provided to 911 personnel so that call centers automatically receive the location and can quickly dispatch responders. According to the FCC, a "dispatchable location" is defined as "the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party." 


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