e911 warning stickers on phones
I'm trying to figure out the FCC requirements for 911 service warning stickers. The FCC documents are rather vague. They say a sticker is required "if there are limitations to the provider's 911 service" but then don't define what constitutes a limitation. Is the fact that the end user can move a handset a "limitation?" Is the likelihood of a power outage also causing a phone outage a "limitation?" So I'm wondering what other hosted service providers are doing? Also, if you provide SIP service to on-premises equipment, do you ship a huge batch of stickers to the customer? Or just include an e911 warning in the contract? Wording of stickers? How do you make them small and unobtrusive on a phone? I considered something that goes under the handset, but that's a small space. Is "E911 WARNING: See this URL" going to be sufficient and compliant? -- Carlos Alvarez TelEvolve 602-889-3003
On 2/24/12 9:10 AM, Carlos Alvarez wrote:
I'm trying to figure out the FCC requirements for 911 service warning stickers. The FCC documents are rather vague. They say a sticker is required "if there are limitations to the provider's 911 service" but then don't define what constitutes a limitation. Is the fact that the end user can move a handset a "limitation?" Is the likelihood of a power outage also causing a phone outage a "limitation?"
Logically yes to both.
So I'm wondering what other hosted service providers are doing?
Also, if you provide SIP service to on-premises equipment, do you ship a huge batch of stickers to the customer? Or just include an e911 warning in the contract?
We put them on the phones that we supply as well as in the contract.
Wording of stickers?
How do you make them small and unobtrusive on a phone? I considered something that goes under the handset, but that's a small space. Is "E911 WARNING: See this URL" going to be sufficient and compliant?
We buy them from Safeguard (805-486-9769) in rolls. About 1/2 inch high by 3/4 inch wide. We put them under the handset. Text reads: "WARNING: 911 service may not be available." -- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV
On Fri, Feb 24, 2012 at 11:14 AM, Jay Hennigan <jay at west.net> wrote:
"WARNING: 911 service may not be available."
Well that's interesting, it's far less explicit that all other examples I've seen so far. The FCC document implies that it should say more, but is very unclear. Is anyone else using something this vague and simple? -- Carlos Alvarez TelEvolve 602-889-3003
I would think the FCC is more concerned with things that are not obvious. Most people understand that a phone with an electric plug doesn't work when the power goes out just as much as they understand when it's not connected to the phone line it won't work. If you have to list obvious things like that, then the whole phone would be covered in one big disclaimer sticker that is so long everyone would just ignore it! Since most people have cell phones and are used to being able to use those to call 911, I think it would be good to state something like "This phone does not have a GPS in it and will not be able to identify your location if you move it to another location." If you are a VOIP provider that does not make people sign 911 waivers, then you could follow that up with an "unless you call this number and update your new location" (or whatever method you use to let them update their location). As for where to put it, I'd put it in plain sight just to be covered legally. Just because the employee who purchased the phones is told the phones won't work if you move them doesn't mean they passed that information onto the rest of the staff! The chances that someone will turn it over and read it are pretty slim to none. Since 911 is one of those things you don't pay attention to until you need it, you want to make it easy for the person making the call to see it. I would also include a disclaimer that in the contract and on the sticker that if someone removes the sticker, the phone provider is no longer liable for not notifying the person dialing 911. Mary Lou Carey BackUP Telecom Consulting CLEC Consultant OFF: 615-791-9969 -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, February 24, 2012 11:11 AM To: voiceops at voiceops.org Subject: [VoiceOps] e911 warning stickers on phones I'm trying to figure out the FCC requirements for 911 service warning stickers. The FCC documents are rather vague. They say a sticker is required "if there are limitations to the provider's 911 service" but then don't define what constitutes a limitation. Is the fact that the end user can move a handset a "limitation?" Is the likelihood of a power outage also causing a phone outage a "limitation?" So I'm wondering what other hosted service providers are doing? Also, if you provide SIP service to on-premises equipment, do you ship a huge batch of stickers to the customer? Or just include an e911 warning in the contract? Wording of stickers? How do you make them small and unobtrusive on a phone? I considered something that goes under the handset, but that's a small space. Is "E911 WARNING: See this URL" going to be sufficient and compliant? -- Carlos Alvarez TelEvolve 602-889-3003 _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
On Fri, Feb 24, 2012 at 12:36 PM, Mary Lou Carey <marylou at backuptelecom.com> wrote:
I would think the FCC is more concerned with things that are not obvious. Most people understand that a phone with an electric plug doesn't work when the power goes out just as much as they understand when it's not connected
Have you ever talked to an END USER? We have actually received calls about the phones not working when the power was out. Funny thing is that a PBX also shuts down without power unless they have a properly-sized battery backup, but end users expect VoIP phones to be like home phones; line powered at all times. And of course we have received the classic call saying, "Our internet and phones are not working. The internet will be fixed tomorrow. Can you fix the phones today?"
you move it to another location." If you are a VOIP provider that does not make people sign 911 waivers, then you could follow that up with an "unless you call this number and update your new location" (or whatever method you use to let them update their location).
We include the location warning in our contract, with a separate initialed section. But only one person sees those.
making the call to see it. I would also include a disclaimer that in the contract and on the sticker that if someone removes the sticker, the phone provider is no longer liable for not notifying the person dialing 911.
So far I'm leaning towards a sticker on the underside of the center of the handset: e911 WARNING This phone may not be able to dial 911 during power outages, if the internet service is down, or at other times. If you move this phone you MUST notify TelEvolve of your new address, otherwise emergency responders may never reach you. -- Carlos Alvarez TelEvolve 602-889-3003
participants (3)
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carlos＠televolve.com -
jay＠west.net -
marylou＠backuptelecom.com