[VoiceOps] 911 address policy for company phones at home
Jon Radel
jradel at vantage.com
Sun Jan 20 11:00:40 EST 2013
My apologies, upon a careful re-reading of your e-mail I retract my
statement about it being out of date, as you may have just phrased part
of it unclearly (at least to this reader):
"If you choose to allow the customer to move their phone then you either
have to place a sticker on the phone stating that 911 service will not
be available to the customer OR you have to provide the customer with a
way to change their address information when they do move the phone."
I believe FCC regulations clearly state that if the phone can be moved
you must provide at least one mechanism for customers to update the
physical location information There has been no "or" in this one since
the interim rules went away years ago. But I may be misunderstanding
your intent here.
In any case, the scenario that Carlos described sounds a lot more, to me
at least, like the customer saying "These phones are going to be
location B but we want to save money by having the PSAP think the call
is coming from location A," rather than "Oh, yes, well, sometimes our
employees might sneak phones out of the building; what can you do?"
By the way, if you read the Vantage Communications document, I believe
you'll find the FCC never complained about us not delivering 911 calls.
They complained about us delivering 911 calls to the wrong PSAP for the
physical location of the phone. Which sounds pretty much like what
Carlos's customer is asking him to do if the employees live far away
enough from work.
And yes, I quite agree that VoIP didn't originate many of the problems
with 911--just made them worse.
--Jon Radel
jradel at vantage.com
267-756-1014
On 1/18/13 3:51 PM, Mary Lou Carey wrote:
>
> I just wanted to point out one thing. The waiver I mentioned is NOT to
> avoid providing 911 service for the customer as it sounds to be the
> case in Vantage's situation. You MUST provide 911 service for the
> customer. The waiver simply states that the 911 service is for the
> single location that the phone was installed and while the phone might
> work if you move it somewhere else, the 911 service will not!
>
> I would fully agree that relying on waivers is risky business -
> especially when it comes to 911. When McDonald's can be held liable
> for someone spilling hot coffee on themselves when they stuck it
> between her legs, you can most certainly be sued for not providing 911
> service when the customer moved their phone. My suggestion would be to
> sign up for the roaming ALI database service so the customers can
> update their location information whenever they move the phone and
> then program the phones so that every time the phone is powered up,
> the customer has to update their location in the ALI database.
> That's really the safest way to operate!
>
> I remember going on an interview years ago to a retail company (who is
> no longer in business) and one of the questions they brought up was a
> problem they were dealing with at the moment. They had two locations
> across the freeway from each other and when someone called the 911
> from one location, the ambulance ended up showing up at the wrong
> building. Through a little investigation we found out that regardless
> of which location someone dialed 911 from, the calls were all routed
> to one number in their PBX. That one number happened to be associated
> with the main building so when 911 was called, that's where the
> ambulance showed up.
>
> Mary Lou Carey
>
> BackUP Telecom Consulting
>
> marylou at backuptelecom.com
>
> Office: 615-791-9969 x 2001
>
> *From:*voiceops-bounces at voiceops.org
> [mailto:voiceops-bounces at voiceops.org] *On Behalf Of *Jon Radel
> *Sent:* Friday, January 18, 2013 12:44 PM
> *To:* voiceops at voiceops.org
> *Subject:* Re: [VoiceOps] 911 address policy for company phones at home
>
> Unless I'm missing something here, you're not proposing to sell
> service to a stationary location and warning the customer that 911
> will break if they fail to notify you that they've moved the phone,
> but you're selling service to stationary location A when the customer
> has already notified you that they'll really be using the phone in
> stationary location B. That really doesn't sound like the same thing
> at all. They've already told you that the phone is going to be in
> location B and you're proposing to not handle 911 appropriately. (My
> apologies if I've misunderstood the situation.)
>
> Be warned that the FCC has clearly signaled that they don't find
> waivers involving 911 the slightest bit amusing. See
> http://www.fcc.gov/document/vantage-communications for their side of
> our story. You might find the references to actual regulatory
> language useful.
>
> I also find myself impelled to ask: Are you actually pricing this in
> such a way that there's a line item for 911 service with a dollar
> figure next to it? That's just inviting the customers to try haggle,
> and could be construed that you consider 911 optional rather than a
> fundamental part of your service. Or is this all just a side-effect
> of charging for the DIDs in the additional rate center(s) where the
> customer's employees live?
>
> Bottom line, however, my advice is that you're treading into waters
> where you *really* *really* want to talk to a competent lawyer with a
> specialty in this arena and not take random advice on a mailing list.
> Not even mine. :-) Getting this wrong could conceivably destroy your
> company.
>
> At the very least, compare what the FCC is currently saying against
> what Mary Lou is saying, some of which appears to be dangerously out
> of date.
>
> --Jon Radel
> jradel at vantage.com <mailto:jradel at vantage.com>
> 267-756-1014
>
> On 1/18/13 1:01 PM, Carlos Alvarez wrote:
>
> Great answer, thanks. This really covers what the customer is
> asking for, which is basically the stationary option (all phones
> show one CLID/ANI/location). I will advise them that it's legal,
> just not advised, and get a written signature for liability.
>
> We do use a 911 service provider, we're not a CLEC. We currently
> provide the ability for a customer to have an address for each
> individual phone if they choose.
>
> On Fri, Jan 18, 2013 at 10:48 AM, Mary Lou Carey
> <marylou at backuptelecom.com <mailto:marylou at backuptelecom.com>> wrote:
>
> Legally VOIP providers have the option to offer roaming VOIP
> services or stationary VOIP services. If you offer roaming
> VOIP you are required to provide your customers with a way to
> update their address information whenever they move their
> phone. It can either be a website they log into to change
> their address or a 24 hour phone number they call, but either
> way you MUST provide it if you allow them to roam. If you do
> allow them to roam you have to get your 911 service from a
> VOIP 911 provider (who has connections to every PSAP in the
> country) or be connected to every PSAP in the country yourself
> because a connection to the LEC network will only cover you
> for the counties or parishes that you establish trunks for.
>
> Most VOIP providers I know sign up with a VOIP 911 provider
> because they cover a large area so it's cheaper to do that
> then have a multitude of connections through the LEC. If you
> decide to go with a stationary VOIP product, you must have the
> customer sign a waiver stating that they are aware that if
> they move their phone they will not receive 911 service. I
> believe the FCC ruled in the last year or so that if you also
> have to place some type of sticker on the phone so that the
> end user who uses the phone knows 911 is not available when
> you move it rather than just the person who ordered the phones.
>
> So the decision is not your customer's, but yours. If you
> choose to allow the customer to move their phone then you
> either have to place a sticker on the phone stating that 911
> service will not be available to the customer OR you have to
> provide the customer with a way to change their address
> information when they do move the phone. While you could offer
> either option to customers based on how much they wanted to
> pay, I would think liability wise it would be better if you
> either offered it to everyone or no one at all because it
> would be too easy for one of your employees to make a mistake
> in setting someone up and not put them on the right plan.
>
> Mary Lou Carey
>
> BackUP Telecom Consulting
>
> marylou at backuptelecom.com <mailto:marylou at backuptelecom.com>
>
> Office: 615-791-9969 x 2001 <tel:615-791-9969%20x%202001>
>
> *From:*voiceops-bounces at voiceops.org
> <mailto:voiceops-bounces at voiceops.org>
> [mailto:voiceops-bounces at voiceops.org
> <mailto:voiceops-bounces at voiceops.org>] *On Behalf Of *Carlos
> Alvarez
> *Sent:* Friday, January 18, 2013 9:51 AM
> *To:* voiceops at voiceops.org <mailto:voiceops at voiceops.org>
> *Subject:* [VoiceOps] 911 address policy for company phones at
> home
>
> We have a customer who wants us to block 911 on the phones
> that they give to key employees to take home. They don't want
> to pay fees for 911 service at each home (which is stupid,
> since it's so cheap, but that's a digression). I told them
> this is "illegal" but they asked to see the law, and I can't
> actually find something that says so. Yet that's the common
> knowledge around the industry. I do have the FCC documents
> that require an ITSP to provide the service, but the customer
> contends it doesn't apply to this specific case.
>
> So two questions...
>
> Does anyone here allow their customers to do this?
>
> What is the best document to give the customer to support our
> position?
>
> --
>
> Carlos Alvarez
>
> TelEvolve
>
> 602-889-3003 <tel:602-889-3003>
>
>
>
> --
>
> Carlos Alvarez
>
> TelEvolve
>
> 602-889-3003
>
>
>
>
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>
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>
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