RAY BAUMS Act - How are people planning on complying?

For those that don't know, RAY BAUMS Act is a new regulation that impacts Emergency Calling. It mandates that a "Dispatchable Location" be included with information to the PSAP when a 9-1-1 call is made in the US. The deadline for compliance is August 1, 2020 (or August 1, 2021 for some scenarios). 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." How are people planning on complying with this? Particularly: 1) When several lines at a site don't have DIDs, and uses a common site phone number for their CLID. How do you provide different location information for them. 2) When there are shared lines on devices in different locations at a site using the same DID. How do you distinguish the correct location of an emergency call made from one of them. 3) When the caller uses a softphone that doesn't have a fixed location. David ---------------------------------------------------------------------- This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

1. Customers will be advised to get enough DIDs to be as specific as needed. For example, smaller locations don't have to be desk-specific, but large locations need to provide enough specificity for the first responder to find the caller. 2. No idea yet. We might just tell customers that if they do this, they are in violation of the law. 3. Nothing, they don't get 911 and they are told so. On Thu, Jan 23, 2020 at 10:11 AM Zilk, David <David.Zilk at cdk.com> wrote:
For those that don?t know, RAY BAUMS Act is a new regulation that impacts Emergency Calling. It mandates that a ?Dispatchable Location? be included with information to the PSAP when a 9-1-1 call is made in the US. The deadline for compliance is August 1, 2020 (or August 1, 2021 for some scenarios).
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.?
How are people planning on complying with this? Particularly:
1) When several lines at a site don?t have DIDs, and uses a common site phone number for their CLID. How do you provide different location information for them.
2) When there are shared lines on devices in different locations at a site using the same DID. How do you distinguish the correct location of an emergency call made from one of them.
3) When the caller uses a softphone that doesn?t have a fixed location.
David ------------------------------ This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system. _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

On 1/23/20 12:10 PM, Zilk, David wrote:
1)When several lines at a site don?t have DIDs, and uses a common site phone number for their CLID.? How do you provide different location information for them.
Most folks I've talked to have been urging customers to get more DIDs for years rather than continuing to hide tons of desks behind a single inbound number with extension dialing. This works well for your typical office and, while not necessarily cheap, comes with obvious additional benefits. For situations where this is either impractical due to cost or silly due to the fact that nobody's going to call those phones directly anyway (e.g. courtesy phones in a warehouse or shopping center), the approach I've heard of is to either have the phone itself add a SIP header or translate from SIP registration identity to location at the SIP proxy and add a similar header defining such a "dispatchable location" which is then passed on to the PSAP. My understanding is that such headers are vendor/operator specific. The latter complicates callback options which I gather is also an issue (I'm not a PSTN regulatory expert by any means, I mostly stick to slinging IP datagrams around). Approach I've heard of is to reserve a few DIDs for E911 callback and re-route them on the fly as outbound 911 calls are placed by putting that in the CLID field. IDK if that's kosher or not.
2) When there are shared lines on devices in different locations at a site using the same DID. How do you distinguish the correct location of an emergency call made from one of them.
The above approach works here, too.
3) When the caller uses a softphone that doesn?t have a fixed location.
This one's complicated. If you control the softphone and it's on a mobile device, you can have it provide you with the device's notion of location, which is often quite accurate especially if GPS is usable, and put that in the aforementioned headers. If you don't control the softphone, or it's on a PC, you're pretty much sunk. You may not be able to even offer service in such situations without taking additional steps. I'm not sure what these new regs have to say about that. In the past, it was pretty well understood at least my reasonably technical folks that you basically had no E911 in these situations. The approach my A-Z terminator takes if you don't have E911 data configured for a DID may be viable. They run their own 911 dispatching service that you get routed to who asks the caller for their location and then routes it, along with the appropriate manually-collected metadata, to the appropriate PSAP. Obviously they charge (handsomely) for this service.

1. Most PBX/UC platform vendors can send a different CLID for emergency calls. Normally this is called the ELI or CESID in the PBX. This emergency CLID of course needs to be set up with the PSAP with the appropriate location information, which is usually handled through the carrier. Granularity requirements vary by state, but the best advice I've heard is to provide enough detail so the first responders know which door to break down. 2. Again, most PBX/UC platforms can handle this without issue, the outgoing CLID does not necessarily have to match an incoming DID, and different CLID can be sent on emergency calls. 3. Generally, softphones are not able to place emergency calls. Make the users sign a disclaimer stating as such. Some softphones can display a reminder message on launch stating they are not to be used for emergency calls. If a remote user has a physical phone at home, disclaimer and a sticker on the phone stating it cannot place emergency calls. On Thu, Jan 23, 2020 at 12:11 PM Zilk, David <David.Zilk at cdk.com> wrote:
For those that don?t know, RAY BAUMS Act is a new regulation that impacts Emergency Calling. It mandates that a ?Dispatchable Location? be included with information to the PSAP when a 9-1-1 call is made in the US. The deadline for compliance is August 1, 2020 (or August 1, 2021 for some scenarios).
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.?
How are people planning on complying with this? Particularly:
1) When several lines at a site don?t have DIDs, and uses a common site phone number for their CLID. How do you provide different location information for them.
2) When there are shared lines on devices in different locations at a site using the same DID. How do you distinguish the correct location of an emergency call made from one of them.
3) When the caller uses a softphone that doesn?t have a fixed location.
David ------------------------------ This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system. _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly. I have NOT been able to get anyone to tell me this for sure, and I've had various trainings on the matter. So I think the answer is "nobody knows" and the answer will cost some company tens of millions of dollars in court. On Thu, Jan 23, 2020 at 10:42 AM Brian Heinz <brian.e.heinz at gmail.com> wrote:
1. Most PBX/UC platform vendors can send a different CLID for emergency calls. Normally this is called the ELI or CESID in the PBX. This emergency CLID of course needs to be set up with the PSAP with the appropriate location information, which is usually handled through the carrier. Granularity requirements vary by state, but the best advice I've heard is to provide enough detail so the first responders know which door to break down.
2. Again, most PBX/UC platforms can handle this without issue, the outgoing CLID does not necessarily have to match an incoming DID, and different CLID can be sent on emergency calls.
3. Generally, softphones are not able to place emergency calls. Make the users sign a disclaimer stating as such. Some softphones can display a reminder message on launch stating they are not to be used for emergency calls. If a remote user has a physical phone at home, disclaimer and a sticker on the phone stating it cannot place emergency calls.
On Thu, Jan 23, 2020 at 12:11 PM Zilk, David <David.Zilk at cdk.com> wrote:
For those that don?t know, RAY BAUMS Act is a new regulation that impacts Emergency Calling. It mandates that a ?Dispatchable Location? be included with information to the PSAP when a 9-1-1 call is made in the US. The deadline for compliance is August 1, 2020 (or August 1, 2021 for some scenarios).
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.?
How are people planning on complying with this? Particularly:
1) When several lines at a site don?t have DIDs, and uses a common site phone number for their CLID. How do you provide different location information for them.
2) When there are shared lines on devices in different locations at a site using the same DID. How do you distinguish the correct location of an emergency call made from one of them.
3) When the caller uses a softphone that doesn?t have a fixed location.
David ------------------------------ This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system. _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

I guess different people have different interpretation of that wording :) To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.

At some point, some ruling body had said those stickers were non-compliant and meaningless. So I think the assumption is that they still see it that way. I think it was the FCC, but not sure. I think to them if it's on a desk and is shaped like a phone, it better work properly for 911. On Thu, Jan 23, 2020 at 12:48 PM Pete Mundy <pete at fiberphone.co.nz> wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care. I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls. To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911 provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database. I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls! MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111 On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service. Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke. Some drive by the ER to get there. So yeah, what Mary said. And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death. I haven't figured out how they will break out responsible parties on all of this. As a hosted provider, are we bound to FORCE people to put phones in the right places? To buy more phones/DIDs and pay for more 911 locations? Or do we need to just tell them that they are responsible for it? I can't quite get a solid answer on this also. For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so. On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care.
I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls.
To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911 provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database.
I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls!
MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

?For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so.? I don?t believe that there is any requirement to have a phone covering every place in the building. The only requirement is that wherever there IS a phone, you have to provide good enough location information to get the first responder to it. If someone needs to hike a mile to get to the phone, that is just the way it is. David From: VoiceOps [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Thursday, January 23, 2020 1:54 PM To: voiceops at voiceops.org Subject: Re: [VoiceOps] RAY BAUMS Act - How are people planning on complying? The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service. Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke. Some drive by the ER to get there. So yeah, what Mary said. And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death. I haven't figured out how they will break out responsible parties on all of this. As a hosted provider, are we bound to FORCE people to put phones in the right places? To buy more phones/DIDs and pay for more 911 locations? Or do we need to just tell them that they are responsible for it? I can't quite get a solid answer on this also. For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so. On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com<mailto:marylou at backuptelecom.com>> wrote: Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care. I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls. To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911 provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database. I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls! MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111 On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com<mailto:caalvarez at gmail.com>> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org<mailto:VoiceOps at voiceops.org> https://puck.nether.net/mailman/listinfo/voiceops<https://urldefense.proofpoint.com/v2/url?u=https-3A__puck.nether.net_mailman_listinfo_voiceops&d=DwMFaQ&c=N13-TaG7c-EYAiUNohBk74oLRjUiBTwVm-KSnr4bPSc&r=VcRLyVxkyGds34uxiPM944HQvaWq-nynyZXfNpSfhOs&m=vM2I0XnFxZOng7VtpuIU9B7ghj7IqZMD1zU7Sx2W8hg&s=71Dfo3wBZmGFLKb9ExGasSrLXWE8msaEYdqK45S1InA&e=>
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I don't think that you would be held responsible if the customer refused to install phones, BUT.......it would be to your benefit to know the laws regarding how many phones are required in a big building because it would help cover your butt at the same time it would increases your sales. So if that company were my customer, I'd say something like .'Did you know that the law requires you to have a working phone every "_____" sq feet? If you don't want to pay the full amount for an outside line, an alternative option that's not as costly for you is to have us set you up with a phone that only connects to the operator and emergency services. That way you're covered if there's an emergency and you don't have to worry about being sued should one of your employees not be able to reach 911 in time!" MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111 On 2020-01-23 03:54 PM, Carlos Alvarez wrote:
The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service. Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke. Some drive by the ER to get there. So yeah, what Mary said. And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death.
I haven't figured out how they will break out responsible parties on all of this. As a hosted provider, are we bound to FORCE people to put phones in the right places? To buy more phones/DIDs and pay for more 911 locations? Or do we need to just tell them that they are responsible for it? I can't quite get a solid answer on this also.
For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so.
On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care.
I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls.
To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911
provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database.
I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls!
MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

I work for Bandwidth and we are a 911 provider. The new law does require the phone companies to make sure they have the right features to be compliant but the law imposes the compliance ON THE ENTERPRISE manager of their phone system. We vendors and carriers have manufacture the car with a seat belt. It is the driver of the car (the enterprise) that gets a ticket if they do not buckle up (comply - as in update the address data). -----Original Message----- From: VoiceOps <voiceops-bounces at voiceops.org> On Behalf Of Mary Lou Carey Sent: Friday, January 24, 2020 11:19 AM To: Carlos Alvarez <caalvarez at gmail.com> Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] RAY BAUMS Act - How are people planning on complying? I don't think that you would be held responsible if the customer refused to install phones, BUT.......it would be to your benefit to know the laws regarding how many phones are required in a big building because it would help cover your butt at the same time it would increases your sales. So if that company were my customer, I'd say something like .'Did you know that the law requires you to have a working phone every "_____" sq feet? If you don't want to pay the full amount for an outside line, an alternative option that's not as costly for you is to have us set you up with a phone that only connects to the operator and emergency services. That way you're covered if there's an emergency and you don't have to worry about being sued should one of your employees not be able to reach 911 in time!" MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111 On 2020-01-23 03:54 PM, Carlos Alvarez wrote:
The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service. Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke. Some drive by the ER to get there. So yeah, what Mary said. And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death.
I haven't figured out how they will break out responsible parties on all of this. As a hosted provider, are we bound to FORCE people to put phones in the right places? To buy more phones/DIDs and pay for more 911 locations? Or do we need to just tell them that they are responsible for it? I can't quite get a solid answer on this also.
For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so.
On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care.
I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls.
To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911
provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database.
I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls!
MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
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An article relevant to this discussion: https://www.nojitter.com/e-911/are-you-ready-new-e911-regulations /Brandon On Fri, Jan 24, 2020 at 10:26 AM Kyle McGinnis <kmcginnis at bandwidth.com> wrote:
I work for Bandwidth and we are a 911 provider. The new law does require the phone companies to make sure they have the right features to be compliant but the law imposes the compliance ON THE ENTERPRISE manager of their phone system. We vendors and carriers have manufacture the car with a seat belt. It is the driver of the car (the enterprise) that gets a ticket if they do not buckle up (comply - as in update the address data).
-----Original Message----- From: VoiceOps <voiceops-bounces at voiceops.org> On Behalf Of Mary Lou Carey Sent: Friday, January 24, 2020 11:19 AM To: Carlos Alvarez <caalvarez at gmail.com> Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] RAY BAUMS Act - How are people planning on complying?
I don't think that you would be held responsible if the customer refused to install phones, BUT.......it would be to your benefit to know the laws regarding how many phones are required in a big building because it would help cover your butt at the same time it would increases your sales.
So if that company were my customer, I'd say something like .'Did you know that the law requires you to have a working phone every "_____" sq feet? If you don't want to pay the full amount for an outside line, an alternative option that's not as costly for you is to have us set you up with a phone that only connects to the operator and emergency services. That way you're covered if there's an emergency and you don't have to worry about being sued should one of your employees not be able to reach 911 in time!"
MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
On 2020-01-23 03:54 PM, Carlos Alvarez wrote:
The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service. Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke. Some drive by the ER to get there. So yeah, what Mary said. And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death.
I haven't figured out how they will break out responsible parties on all of this. As a hosted provider, are we bound to FORCE people to put phones in the right places? To buy more phones/DIDs and pay for more 911 locations? Or do we need to just tell them that they are responsible for it? I can't quite get a solid answer on this also.
For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage. They have balked at putting phones out ever 6-7k square feet on poles and such. Is that our problem? I don't think so.
On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
Logically it makes sense that if your phone says it can't make 911 calls, you would look for another phone. The problem is that when people are in survival mode or trauma mode, they don't do things that make sense! When I was much younger I worked for a medical clinic and I remember them telling us that if there's a natural disaster people may show up at the clinic thinking it's a hospital because when people are in trauma mode, they don't think rationally. They'll do crazy things.....like call their doctor when they're having a heart attack and ask if they should go to the hospital or show up at a clinic thinking it's a hospital and demand immediate care.
I think the same mentality applies here. People see a phone and if it has a dial tone they will attempt to make a 911 call regardless of whether there's a sticker stating that it can't make 911 calls. So its always best to provide 911 service if your customers can originate calls.
To get 911 service for your customers you can either order 911 trunks for each county through the ILEC (the expensive route) or you can connect with a VOIP 911 provider that will establish two diverse connections between them and your switch. You just send the VOIP 911
provider the traffic and they'll take care of routing your calls to the appropriate PSAP. You're just responsible for keeping your customer's address location up to date in the ALI database.
I know at one time that there was a ruling that you had to provide your customer a way to update their location if you allowed them to move their phone to another location. I don't know if that was changed or the work around still remains that you can put a sticker on the phone stating that if you move your phone to another location it may not connect to the right 911 center. At any rate.....I wouldn't mess around with providing 911 services because the FCC doesn't consider it optional. The only waiver I"m aware of is the one that states your customers are only terminating traffic onto your network....not making any originating calls!
MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
On 2020-01-23 01:47 PM, Pete Mundy wrote:
I guess different people have different interpretation of that wording :)
To me it seems UNreasonable to assume that a phone or device with a sticker on it that says "This phone does not work for emergency calls" can call emergency services.
On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com> wrote:
I believe that the stickers on home phones may not really cover the liability. The wording is something like: A phone or device that a person would reasonably assume can call emergency services." So the softphone is obviously different, but a physical phone at home seems like it must still work properly.
VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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participants (8)
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brian.e.heinz@gmail.com
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bsvec@teamonesolutions.com
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caalvarez@gmail.com
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David.Zilk@cdk.com
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kmcginnis@bandwidth.com
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lists.voiceops@monmotha.net
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marylou@backuptelecom.com
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pete@fiberphone.co.nz