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

Kyle McGinnis kmcginnis at bandwidth.com
Fri Jan 24 13:25:31 EST 2020


I work for Bandwidth and we are a 911 provider.  The new law does require
the phone companies to make sure they have the right features to be
compliant but the law imposes the compliance ON THE ENTERPRISE manager of
their phone system. We vendors and carriers have manufacture the car with
a seat belt. It is the driver of the car (the enterprise) that gets a
ticket if they do not buckle up (comply - as in update the address data).

-----Original Message-----
From: VoiceOps <voiceops-bounces at voiceops.org> On Behalf Of Mary Lou Carey
Sent: Friday, January 24, 2020 11:19 AM
To: Carlos Alvarez <caalvarez at gmail.com>
Cc: voiceops at voiceops.org
Subject: Re: [VoiceOps] RAY BAUMS Act - How are people planning on
complying?

I don't think that you would be held responsible if the customer refused
to install phones, BUT.......it would be to your benefit to know the laws
regarding how many phones are required in a big building because it would
help cover your butt at the same time it would increases your sales.

So if that company were my customer, I'd say something like .'Did you know
that the law requires you to have a working phone every "_____" sq feet?
If you don't want to pay the full amount for an outside line, an
alternative option that's not as costly for you is to have us set you up
with a phone that only connects to the operator and emergency services.
That way you're covered if there's an emergency and you don't have to
worry about being sued should one of your employees not be able to reach
911 in time!"


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

On 2020-01-23 03:54 PM, Carlos Alvarez wrote:
> 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> 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>
>> 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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