The New Year will kick off with a new set of laws – Kari’s Law and RAY BAUM’s Act – going into effect across the nation. While the exact provisions of each law are different, they work together to enhance the safety of those using Multi-line Telephone Systems (MLTS).  Barry Communications Karis Law RAY BAUMS law

In this post, we’re taking a look at each of the laws and what it means for Barry Communications customers.

Kari’s Law

Kari’s Law applies only with respect to multi-line telephone systems (MLTS) that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

Kari’s Law requires MLTS systems in the United States to enable users to dial 911 directly, without having to dial a prefix to reach an outside line, and to provide for notification (e.g., to a front desk or security office) when a 911 call is made.

RAY BAUM’S Act

RAY BAUM’S Act requires the Commission to conduct a rulemaking proceeding to consider adopting rules to ensure that “dispatchable location” is conveyed with 911 calls, regardless of the technological platform used, so that 911 call centers will receive the caller’s location automatically and can dispatch responders more quickly. “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.”

Casey Hutchinson recently reached out to the Massachusetts State 911 Department for clarification on each of the laws, which has been summarized below. It should be noted that the Massachusetts 911 Department. has not finalized/published its interpretation of Kari’s Law and therefore was unable to provide any written confirmation as it is currently in draft form.  

  • Kari’s Law and RAY BAUM’s Act apply in their entirety to any system manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.
  • Massachusetts 911 Department will state that any system that is capable of complying, must comply. *
  • Massachusetts 911 Department requires that any system that is not capable of direct dialing 911 should have a sticker placed on the device with clear 911 dialing instructions.
  • Non-complying systems are not necessarily grandfathered indefinitely.*
  • The FCC interpretation is that Kari’s Law only applies to systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.
  • Customers must have an Emergency Response Location (ERL) Identifier per 22,500 square feet and a unique identifier per floor and room number or unit number.
  • Non-fixed on-prem devices (softphones) have the same requirements as fixed devices where technically feasible with a compliance date of February 2022*
  • Non-fixed off-prem devices (softphones/remote phones) have the same requirements as fixed devices where technically feasible, or with improvement at a reasonable cost with a compliance date of February 2022*

Our Recommendations

In response to the forthcoming Kari’s Law and Ray Baum’s Act compliance date, we at Barry Communications wanted to offer our guide for best practice as it relates to these regulations. While Kari’s Law specifically applies to phone systems that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020, Massachusetts will have its own interpretation. Based on our discovery and communication with the Massachusetts 911 Department we have arrived at the following best practice directives:

  • Your phone system, if capable, should be configured to dial 911 directly, without having to dial a prefix to reach an outside line. If your system is not capable of dialing 911 without a prefix, a sticker should be placed on every device with clear instructions for dialing 911.
  • Your phone system, if capable, should be configured to deliver an alert to a central location via text message, phone call, audible alert, or email.
  • When dialing 911, your phone system, if capable, should provide a dispatchable Emergency Response Location (ERL) Identifier per 22,500 square feet and unique identifier per floor and room number or unit number. To use a multi-floor location as an example, the 911 operation should receive the front door address of the location as well as the floor and suite number.

While it is our understanding that currently there is no defined period that a technically non-compliant system may stay in operation, we suggest that all efforts be made to attain compliance.

Please reach out to our team service@barrycommunications.com or (508) 853-7120 for any and all configuration assistance in achieving compliance. Additionally, please feel free to reach out to the Massachusetts 911 Department for additional information and clarification.