Kari’s Law – Direct Dialing and Notification for Multi-Line Telephone Systems

Background: Kari’s Law is named in honor of Kari Hunt, who was killed by her estranged husband in a motel room in Marshall, Texas in 2013.  Ms. 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. 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 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.

 

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

 

Rule: 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;
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.  (47 CFR § 9.3.)

 

RAY BAUM’S Act – Dispatchable Location for MLTS

 

Under Section 506 of RAY BAUM’S Act, the Commission has adopted rules to ensure that “dispatchable location” is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from MLTS.  Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party.  (47 CFR § 9.3.)

 

Frequently Asked Questions: 

Q: Does Kari’s Law apply to all MLTS or are some MLTS grandfathered?

A: Kari’s Law applies to all MLTS in the U.S. that are manufactured, imported, offered for first sale or lease, first sold, or leased, or installed on or after February 17, 2020. It does not cover existing MLTS that were installed prior to February 17, 2020. However, in some states, existing MLTS that are not covered by the federal version of Kari’s Law may be covered by state versions of Kari’s Law that were enacted prior to the federal law.

 

Q: Since Kari’s Law does not apply to pre-February 17, 2020 MLTS, is it still possible that I may have to dial “9” first before calling 911 from a hotel, business, or other enterprise phone system?

A: Yes. Because the statute is not retroactive, some hotels, workplaces, and other locations may have legacy MLTS equipment that still requires dialing an extra digit to call 911. If you are unfamiliar with the phone system in a hotel, office, or other location, it is important that you inquire about how the system handles dialing 911. We also strongly encourage enterprises to include labels or warnings regarding the 911 dialing capabilities of legacy MLTS devices.