[VoiceOps] RAY BAUMS Act - How are people planning on complying?

Thu Jan 23 17:00:02 EST 2020

“For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage.  They have balked at putting phones out ever 6-7k square feet on poles and such.  Is that our problem?  I don't think so.”

I don’t believe that there is any requirement to have a phone covering every place in the building.  The only requirement is that wherever there IS a phone, you have to provide good enough location information to get the first responder to it.  If someone needs to hike a mile to get to the phone, that is just the way it is.

David

From: VoiceOps [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez
Sent: Thursday, January 23, 2020 1:54 PM
To: voiceops at voiceops.org
Subject: Re: [VoiceOps] RAY BAUMS Act - How are people planning on complying?

The number one user of 911 service for us is a chain of urgent care clinics that use our hosted service.  Several times a week, someone will casually walk in saying they think they're having a heart attack or stroke.  Some drive by the ER to get there.  So yeah, what Mary said.  And if you read the cases that lead to these laws, you will see a string of poor decisions leading to injury and death.

I haven't figured out how they will break out responsible parties on all of this.  As a hosted provider, are we bound to FORCE people to put phones in the right places?  To buy more phones/DIDs and pay for more 911 locations?  Or do we need to just tell them that they are responsible for it?  I can't quite get a solid answer on this also.

For example, we have a customer whose manufacturing facility is well over the size that would allow a phone or two as legal coverage.  They have balked at putting phones out ever 6-7k square feet on poles and such.  Is that our problem?  I don't think so.

On Thu, Jan 23, 2020 at 1:21 PM Mary Lou Carey <marylou at backuptelecom.com<mailto:marylou at backuptelecom.com>> wrote:
Logically it makes sense that if your phone says it can't make 911
calls, you would look for another phone. The problem is that when people
are in survival mode or trauma mode, they don't do things that make
sense! When I was much younger I worked for a medical clinic and I
remember them telling us that if there's a natural disaster people may
show up at the clinic thinking it's a hospital because when people are
in trauma mode, they don't think rationally. They'll do crazy
things.....like call their doctor when they're having a heart attack and
ask if they should go to the hospital or show up at a clinic thinking
it's a hospital and demand immediate care.

I think the same mentality applies here. People see a phone and if it
has a dial tone they will attempt to make a 911 call regardless of
whether there's a sticker stating that it can't make 911 calls. So its
always best to provide 911 service if your customers can originate
calls.

To get 911 service for your customers you can either order 911 trunks
for each county through the ILEC (the expensive route) or you can
connect with a VOIP 911 provider that will establish two diverse
connections between them and your switch. You just send the VOIP 911
provider the traffic and they'll take care of routing your calls to the
appropriate PSAP. You're just responsible for keeping your customer's
address location up to date in the ALI database.

I know at one time that there was a ruling that you had to provide your
customer a way to update their location if you allowed them to move
their phone to another location. I don't know if that was changed or the
work around still remains that you can put a sticker on the phone
stating that if you move your phone to another location it may not
connect to the right 911 center. At any rate.....I wouldn't mess around
with providing 911 services because the FCC doesn't consider it
optional. The only waiver I"m aware of is the one that states your
customers are only terminating traffic onto your network....not making
any originating calls!

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2020-01-23 01:47 PM, Pete Mundy wrote:
> I guess different people have different interpretation of that wording
> :)
>
> To me it seems UNreasonable to assume that a phone or device with a
> sticker on it that says "This phone does not work for emergency calls"
> can call emergency services.
>
>
>> On 24/01/2020, at 6:46 AM, Carlos Alvarez <caalvarez at gmail.com<mailto:caalvarez at gmail.com>> wrote:
>>
>> I believe that the stickers on home phones may not really cover the
>> liability.  The wording is something like:  A phone or device that a
>> person would reasonably assume can call emergency services."  So the
>> softphone is obviously different, but a physical phone at home seems
>> like it must still work properly.
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