[VoiceOps] e911 warning stickers on phones

Mary Lou Carey marylou at backuptelecom.com
Fri Feb 24 14:36:44 EST 2012

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
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VoiceOps at voiceops.org

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