Xeta Group
KARI'S LAW
DIRECT DIALING AND NOTIFICATION FOR
MULTI-LINE TELEPHONE SYSTEMS (MLTS)
Kari's Law – Direct Dialing and Notification for multi-line telephone systems (MLTS)

What Is "Kari's Law"?

Kari's Law ensures that anyone can reach a 911 call center when dialing 911 from an Multi-Line Telephone system (MLTS). 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.

The Kari's 911 Law recently came into effect on February 16, 2020. There are two main components to Kari's Law:

Kari's law is an amendment to the FCC's Communications Act that enables direct dialing of 9-1-1. It mandates that any multi-line telephone system (MLTS) allows users to dial 9-1-1 without having to dial a prefix, like 9,8, or 0. In other words, to dial 9-1-1, there's no extra 9 needed.

It also dictates that a notification is sent (e.g., floor and room number within a building) to security officials or building administrators for an MLTS, to rapidly dispatch assistance or first-aid, either through a text, an email, or a phone call.

Kari's Law Compliance Date

The statute provides that these requirements take effect on February 16, 2020, two years after the enactment date of Kari's Law. In addition, Kari's Law and the federal rules are forward-looking and apply only with respect to any MLTS that are manufactured, imported, offered for first sale or lease, first sold, or leased, or installed after February 16, 2020.

Kari's Law Story

The campaign to pass Kari's Law began in December 2013, when the namesake of the bill, Kari Hunt was murdered by her estranged husband in a hotel room in Marshall, Texas. Hunt's 9-year-old daughter tried to call 911 for help four times from the motel room phone, but the call never went through because she did not know that the motel's phone system required dialing "9" for an outbound line before dialing 911. Kari's father, Hank Hunt made a promise to his granddaughter that this would never happen to another child. He worked tirelessly over the next four years to get laws passed at both the state and federal levels.

Kari's Law 911 Legislation

In August 2019, the Commission adopted rules implementing two federal laws that strengthen emergency calling: Kari's Law and Section 506 of RAY BAUM'S Act.

Kari's Law 911 legislation requires the configuration allowing users to directly initiate a call to 9-1-1 without dialing any additional digit, code, prefix, or postfix. Separate versions of the bill were initially passed in 2017 in the House and Senate. Committees then worked to combine the two versions into a single bill H.R. 582.

Congress responded by enacting Kari's Law in 2018. Kari's Law requires direct 911 dialing and notification capabilities in multi-line telephone systems (MLTS), which are typically found in enterprises such as office buildings, campuses, and hotels. The statute provides that these requirements take effect on February 16, 2020, two years after the enactment date of Kari's Law. In addition, Kari's Law and the federal rules are forward-looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

Under the statute and the Commission's rules, MLTS manufacturers and vendors must pre-configure these systems to support direct dialing of 911—that is, to enable the user to dial 911 without having to dial any prefix or access code, such as the number 9. In addition, MLTS installers, managers, and operators must ensure that the systems support 911 direct dialing.

The Commission's rules also implement the notification requirement of Kari's Law, which is intended to facilitate building entry by first responders. When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification shall include, at a minimum, the following information:

  1. The fact that a 911 call has been made;
  2. A valid callback number; and
  3. The information about the caller's location that the MLTS conveys to the public safety answering point (PSAP) with the call to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information.
Kari's Law Compliance date (MLTS direct dialing and notification) and Exemption for Legacy MLTS
Kari's Law and the Commission's rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold, or leased, or installed on or before February 16, 2020.

All other MLTS (i.e., systems manufactured, imported, offered for first sale or lease, first sold, or leased, or installed after February 16, 2020) must meet the following compliance date:

Feb. 17, 2020: *

MLTS manufacturers, importers, sellers, and lessors:

  • May not manufacture or import for use in the United States, or sell or lease or offer to sell or lease in the United States, an MLTS, unless the system is pre-configured so that when it is properly installed in accordance with the MLTS rules, a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for the other calls.
MLTS installers, managers, and operators:

  • May not install, manage, or operate for use in the United States an MLTS, unless the system is configured so that a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for other calls.
  • Shall, in installing, managing, or operating an MLTS for use in the United States, configure the system to provide MLTS notification to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system. MLTS notification must meet the following requirements:
  1. It must be initiated contemporaneously with the 911 call, provided that it is technically feasible to do so; and
  2. It must not delay the call to 911; and
  3. It must be sent to a location where someone is likely to see or hear it.

Kari's Law Questions Answered

What is "Karis Law"?
The Kari's 911 Law recently came into effect on February 16, 2020. There are two main components to Kari's Law: Kari's law is an amendment to the FCC's Communications Act that enables direct dialing of 9-1-1. It mandates that any multi-line telephone system (MLTS) allows users to dial 9-1-1 without having to dial a prefix, like 9,8, or 0. In other words, to dial 9-1-1, there's no extra 9 needed.

It also dictates that a notification is sent (e.g., floor and room number within a building) to security officials or building administrators for an MLTS, to rapidly dispatch assistance or first-aid, either through a text, an email, or a phone call.
What Are The Kari's Law 911 requirements?
Kari's Law applies to multi-line telephone systems ("MLTS") "manufactured, imported, offered for first sale or lease, first sold or leased, or installed" after the compliance date of February 16, 2020. It requires:

REQUIRING A "PREFIX" WHEN CALLING 911 IS PROHIBITED
Locations with MLTS must remove any requirement that a caller dial "9", "8", or any other number to reach an outside line to make a call to 911.

ON-SITE NOTIFICATIONS
When a 911 call is placed from an MLTS, a notification must be sent to on-site personnel, alerting them to the emergency. The notifications to the appropriate contact can take the form of phone calls, visual alerts on a monitor, audible alarms, text messages, and/or emails.
When Did Kari's Law Go Into Effect?
Kari's Law compliance date started on February 17, 2020
What Does Kari's Law Affect?
Kari's Law applies to multi-line telephone systems ("MLTS") "manufactured, imported, offered for first sale or lease, first sold or leased, or installed" after the compliance date of February 16, 2020.
Are There Any Kari's Law Exemptions?
Kari's Law and FCC rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020.
What Does Kari's Law Have To Do With Call Location?
In addition to guaranteeing that anyone can direct dial 9-1-1 for help, Kari's Law, as well as the Ray Baum Act, aim to ensure that anyone calling 9-1-1 will be able to be found, no matter where they're calling from.

As we know, VoIP and mobile phones don't have a local address attached when they call 9-1-1, like a landline phone would, so it makes identifying the location of a call dependent on verbally relayed information. During an emergency, a caller might not know where they are, or be able to provide enough specific context to be easily found by first responders.

Kari's Law was passed alongside the Ray Baum Act to ensure that a dispatchable location is sent along to an Emergency Communications Center (ECC) when 9-1-1 is dialed through an MLTS, so that first responders will be better able to find callers in need.
How Will The 911 Kari's Law Change Public Safety?
By ensuring that MLTS phones no longer need to enter a prefix to dial 9-1-1, Kari's Law will expedite emergency calls and deliver help faster than ever to the occupants of enterprise-level buildings.

Whether they're school kids, travelers, office employees, or hotel workers, Kari's Law will not only avert any confusion they might experience in an emergency, but it will also help send accurate location data along to first responders.

Having access to precise location data revolutionizes our approach to public safety. First responders will save time searching for callers and can instead focus their efforts on getting to the scene as fast as possible. Considering how many lives are lost each year because first responders couldn't find who they were trying to help, having access to this data will undoubtedly cut that number down.
What Is a Multi Line Telephone System
A multi-line phone system lets you handle two or more calls simultaneously. It enables employees to place calls on hold, dial internal or external numbers, and return to the line.

Multi-line phones differ from phones with a single line that can only maintain one phone call at a time. Likewise, they have one phone number assigned to them. When the line is in use, callers will be directed to a voicemail or a busy signal.

What Is The Ray Baum Act?
The Ray Baum Act, among other things, mandates that a dispatchable location is sent whenever possible through an MLTS phone. However, when a dispatchable location can't be sent automatically, it can be relayed manually either through an end user (like a front desk security guard) or through other means.
Who's Affected by Kari's Law and RAY BAUM's Act?
Both Kari's Law and RAY BAUM's Act impact enterprises using multi-line telephone systems (MTLS), such as:

• Companies with offices in multiple locations
• Campuses–including K-12, universities, and colleges
• Hospitals
• Hotels
• Retail facilities
• Financial institutions
• Warehouses

References

Federal Communications Commission. (2019) Implementing Kari's Law and Section 506 of RAY BAUM'S Act, 911 Access, Routing, and Location in Enterprise Communications Systems, Amending the Definition of Interconnected VoIP Service in Section 9.3 of the Commission's Rules. (Report No. FCC-19-76).Retrieved from https://www.fcc.gov/document/fcc-improves-access-911-and-timely-assistance-first-responders-0

Multi-line Telephone Systems – Kari's Law and RAY BAUM'S Act 911 Direct Dialing, Notification, and Dispatchable Location Requirements https://www.fcc.gov/mlts-911-requirements
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