Shrinking the E911 SpaceShrinking the E911 Space
First it was the address, then within 40,000 square feet, then 25,000 square feet and now 7,000 square feet for E911 location information. Slowly, some states are filling the hole left by the FCC, but not consistently. They are passing legislation against the wishes of enterprises, hotels, health care, banking and higher education institutions, your employers, because of the costs. Imagine the lawsuit that will be issued if these organizations choose not to implement E911.
February 25, 2008
First it was the address, then within 40,000 square feet, then 25,000 square feet and now 7,000 square feet for E911 location information. Slowly, some states are filling the hole left by the FCC, but not consistently. They are passing legislation against the wishes of enterprises, hotels, health care, banking and higher education institutions, your employers, because of the costs. Imagine the lawsuit that will be issued if these organizations choose not to implement E911.
First it was the address, then within 40,000 square feet, then 25,000 square feet and now 7,000 square feet for E911 location information. Slowly, some states are filling the hole left by the FCC, but not consistently. They are passing legislation against the wishes of enterprises, hotels, health care, banking and higher education institutions, your employers, because of the costs. Imagine the lawsuit that will be issued if these organizations choose not to implement E911.The FCC issued requirements for E911 for wireless carriers in June 1996, order 96-264. The FCC announced in December 2003 that it would NOT adopt similar orders for multi-line wired systems and left it up to the states to adopt their own requirements. What will be the impact as more states adopt varying E911 compliance requirements?
The state of Virginia passed legislation in March 2007 that mandates emergency calls placed by any multi-line telephone system installed after July 1, 2009 must have Automatic Number Identification (ANI) and Automatic Location Identification (ALI) information. This requires that any facility of over 7,000 square feet of contiguous area must be compliant. The Virginia statute does not call for any penalties because those fighting for passage had to compromise to get this law enacted. See Virginia House Bill NO. 1603 . Illinois requires location information for 40,000 square feet or more. Illinois can fine an enterprise up to $5,000 for not implementing their statute. Washington uses 25,000 square feet for their location criteria. If OSHA possibly gets involved, then the fine could be as high as $70,000 because of workplace safety issues.
One of the reasons for the Virginia enactment was the headline Man Found Dead in Office 10 Hours After 911 Phone Glitch Confuses Rescuers , in the Washington Post, published April 21, 2006.
The Post article said. Kaafee Billah walked into his Gaithersburg office shortly before 9 a.m. Tuesday. The 39-year-old sales representative, who had recently started working at the medical company MedImmune Inc., made the first call from his desk at 9:02. Roughly 40 minutes later, he called 911 to say he needed medical help.
Almost 10 hours passed before someone found his body lying on the floor. Police say an apparent phone glitch sent emergency personnel to the wrong address, leading them to believe that the 911 call was unfounded.
Imagine this headline at your place of work. As E911 technology becomes available, there is no excuse for not implementing E911 information services. I was prompted to write this blog by an article in the Telcom Manager s Voice Report , published as New State Laws Add Reason to Get E911 Right.
The emerging risks for the E911 issue are:
Workplace mobility, how stable is the employee location during the work day.
Infrastructure complexity and work environment (number of sites, buildings, geographic area, number of floors )
The E911 readiness plan, whether it exists, how well is it written and how well can it be executed.
RedSky Technologies, a developer of E911 location support products, has introduced a free E911 Risk Assessment questionnaire which can be taken on their Web site. The assessment collects information (14 multiple choice questions) about an enterprise. It defines potential areas of risk in terms of workplace safety and corporate liability for E911. RedSky also has an on line database of the statutes for those states that have enacted or are pending enaction for E911 regulations.
If you are concerned about what may be enacted in your state, there is a Proposed Model Legislation, Enhanced 9-1-1 for Multi-line Telephone Systems from the National Emergency Number Association (NENA).
So let s return to the E911 regulations. There will be costs for the E911 software, location collection technology that may be integrated in the LAN switch for IP phones, an update to legacy PBXs, added costs to key systems and improved emergency notification procedures.
The software cost can be thousands of dollars. The LAN switch equipment may have to be replaced. Another cost is the potential fine for non-compliance and the liability and insurance costs if the response to an E911 incident is not successfully met. What makes it even more confusing is the enterprise s implementations of E911 will probably be different in each state.
My concern is that if an entrprise implements an effective E911 solution in one state but not in another because it is not required there, will the entrprise still be liable in the state that does not call for E911 location information enforcement? I am sure the suing lawyers will point out that the enterprise chose to be less or not at all responsive to the E911 capabilities. Does this mean that all sites of a multi-state enterprise have to have equal E911 capabilities? I don t know, as there seems to be no court cases yet, but you can be sure they are coming.
RedSky Technologies, a developer of E911 location support products, has introduced a free E911 Risk Assessment questionnaire which can be taken on their Web site. The assessment collects information (14 multiple choice questions) about an enterprise. It defines potential areas of risk in terms of workplace safety and corporate liability for E911. RedSky also has an on line database of the statutes for those states that have enacted or are pending enaction for E911 regulations.
If you are concerned about what may be enacted in your state, there is a Proposed Model Legislation, Enhanced 9-1-1 for Multi-line Telephone Systems from the National Emergency Number Association (NENA).
So let s return to the E911 regulations. There will be costs for the E911 software, location collection technology that may be integrated in the LAN switch for IP phones, an update to legacy PBXs, added costs to key systems and improved emergency notification procedures.
The software cost can be thousands of dollars. The LAN switch equipment may have to be replaced. Another cost is the potential fine for non-compliance and the liability and insurance costs if the response to an E911 incident is not successfully met. What makes it even more confusing is the enterprise s implementations of E911 will probably be different in each state.
My concern is that if an entrprise implements an effective E911 solution in one state but not in another because it is not required there, will the entrprise still be liable in the state that does not call for E911 location information enforcement? I am sure the suing lawyers will point out that the enterprise chose to be less or not at all responsive to the E911 capabilities. Does this mean that all sites of a multi-state enterprise have to have equal E911 capabilities? I don t know, as there seems to be no court cases yet, but you can be sure they are coming.
