HOW TO ENSURE E911 COMPLIANCE

Let’s quickly review what enhanced 911 (E911) means. This new Michigan legislation is designed to ensure that a caller’s callback number and specific location within your building are delivered to the correct Public Safety Answering Point (PSAP), the call centers answering emergency calls and dispatching emergency services. (To learn more, read “What is Enhanced 911 and How Does it Affect Your Business”).

Basically, the legislation which is already in effect in Michigan requires all multi-line telephone systems (MLTS) or Private Branch Exchange (PBX) operators/owners to comply with new regulations by the end of 2019 or potentially face fines. You can review the Federal Communications Commission requirements here. 

Understanding the New Requirements

The requirements for E911 vary based on the number of buildings and square footage of your enterprise. In general, the specific location of each communications device needs to be provided. Why is location information so important? There are many reasons a person calling 911 might not be able to communicate his or her specific location to the 911 dispatcher, including being a young child, choking, heart attack or other injuries that prevent someone from speaking.

In order to better understand the new regulations, it’s helpful to review how 911 calls work in general. Let’s say John Smith calls 911 from his wired residential telephone. The 911 dispatcher receiving the call sees the location of the caller’s phone on a special computerized phone screen – that information is called Automatic Location Identification (ALI). The dispatcher typically sees the caller’s telephone number, the name from the billing record, the street address, city and state. It may also include an apartment or building number. This information was provided by John’s phone company and stored in a centralized 911 database (the ALI database) that is maintained as part of the centralized 911 system in Michigan.

It’s important to note that the phone company is responsible for entering and submitting John’s street address and city name. The information provided must be an address and city that can be found on the Master Street Addressing Guide (MSAG), a list of street names and permissible numbers entered into the 911 system database.

When an MLTS system does NOT provide emergency location, the process works differently. Let’s say John calls from his office, which has an MLTS or PBX phone system that provides phone services for several buildings that are clustered together in a complex. If he calls from his third floor cubicle, in Building B located at 100 Main Street, the information the dispatcher receives is much less useful, or in some cases, downright misleading.

By becoming E911 compliant, specific information regarding the caller’s location is relayed to the dispatcher, including building number, floor number and even room number. This type of information avoids emergency response delays and resulting tragedies, especially in large building complexes. The new rules will ensure that the 911 dispatchers at Michigan’s PSAPs receive accurate, specific location information, as well as a callback number.

The MLTS under compliance is also required to provide an Emergency Response Location (ERL), which is a specific location to which emergency response services may be dispatched and can be easily located by emergency responders in a reasonable amount of time.

Do the Rules Apply to Me?

The new rules obligate ALL operators of MLTS/PBX to route 911 calls and specific location information to the appropriate local PSAP when 911 is dialed. The rules require specific information which indicates the precise location of the calling device.

The type of specific information that must be provided is determined by the type of structure(s) served by your MLTS. Are you an MLTS operator or a manager? According to the guidelines, “An MLTS operator is the entity responsible for ensuring that a 911 call is transmitted and received in accordance with this model, regardless of the technology used to make the call. The MLTS operator may be the MLTS manager or could be a third party acting on behalf of the MLTS manager. By default, in the absence of evidence to the contrary, the entity using the MLTS system (business, school, hospital, etc.) is considered the MLTS operator. The MLTS manager is the entity authorized to implement an MLTS, either by purchase or lease of an MLTS.”

The rules place the responsibility and liability on the MLTS operator. As if this is not complicated enough, like so many regulations, there are a list of exemptions that may apply.

How Do I Know If I Am Compliant?

The Michigan Public Service Commission (MPSC) provides a complete guide to the regulations but the rules vary by locations and capabilities of MLTS systems. They strongly suggest that companies communicate with their local 911 service providers and telecommunications equipment provider to ensure compliance. Local public safety entities can provide specific guidance as to what constitutes compliance and what is considered “best practices”.

When working with public safety entities and your telecommunications equipment providers, consider the following questions:

• How many locations do I have?
• How many PSAPs does my MLTS need to access?
• Do I have remote users, and can they access 911?
• Do I need to establish an internal process to ensure movement of equipment does not interfere with the provision of accurate information to 911 responders?
• How can I integrate on-site security in response process?
• What training and certification do they need?

It is recommended that MLTS operators work with their local 911 system manager/director to test the ability to dial 911 whenever a system is installed or upgraded. A current list of all 911 PSAPs can be found at www.michigan.gov/snc.

(MLTS implementation and regulation guidelines can be found at www.michigan.gov/documents/msp/FINAL_MLTS_Guidelines_503991_7.pdf)

Need more help? Millennia Technologies has been a leader in the telecommunications industry for over 30 years. We’re committed to helping our clients understand what these new regulations mean to your business and helping you become E911 compliant. Give us a call at 866-240-2500.

Sources:

• ¹“911 and E911 Services,” Federal Communications Commission – https://www.fcc.gov/general/9-1-1-and-e9-1-1-services
• “Guidelines for Multi-Line Telephone Systems,” July 2018 – Michigan www.michigan.gov/documents/msp/FINAL_MLTS_Guidelines_503991_7.pdf
• “Is your business subject to the new State of Michigan E911 Regulations?” Telecom professionals

For state-specific information, click here