Anyone offering 911 services to businesses should be familiar with Ray Baum’s Act. I’ve written about it before (read the linked article if you need the background), but in summary, it’s all about making sure that 911 operators are able to identify a dispatchable location (more accurate than just the street address) for a 911 call – whether the caller is using a fixed line or even a non-fixed VoIP line.
This is a pretty challenging requirement for service providers offering Hosted PBX and UCaaS services, and in this article I’d like to summarize some of the key issues you need to be thinking about to ensure you’re compliant with the law. [Note: I am not a lawyer, this is intended to be helpful but is not be comprehensive.]
ALI Database Updates
Perhaps the most important element of Ray Baum is that the Automatic Location Identification database contains accurate locations (including floors, suites, buildings) for every phone number that could place a 911 call, including individual DIDs within a business. It’s no longer enough to signal the primary DN for all 911 calls and have first responders show up at the front office of a large complex.
“Fixed” Phone Lines
But it’s not just about adding more information, this information also needs to be kept up to date. If Joey gets transferred to a different department in a different building, but keeps the same phone number, the ALI database needs an update for Joey’s phone number.
So we reach two conclusions:
- You really need to push this responsibility down to the IT/Phone Administrators (or even the end-users) in the business – as the service provider doesn’t have the knowledge to make these changes.
- You would ideally provide a simple method for the end-users to make these updates. Metaswitch CommPortal provides a way of doing this within a subscriber account, but only if you’re using Intrado for 911.
Ideally you would be able to provide a secure portal for end-users to make these changes, but at the very least you need to make them aware that they need to contact you (their service provider) if a phone number changes location. I’ve heard of some folks who put stickers on every phone warning users of this requirement – including one next to the Ethernet port so you see it anytime you unplug the phone.
Moveable Phone Lines
As we’ve seen above, hardly any business phones are truly fixed in place, but if they move infrequently, then (in my view) it’s possible to take a fairly manual approach to updating the ALI database – just as long as you communicate clearly what is needed.
Things get more complicated with phones that are designed to move frequently – and in particular I’m thinking about soft-clients, such as Max UC. As we think about how Ray Baum applies for soft-clients, we need to consider a few different scenarios:
- A soft-client running on a cell phone – which is a special case due to the native phone function of the cell phone.
- A phone that moves around the business location – such as a worker using a laptop or tablet who regularly moves to different conference rooms or parts of the business campus.
- A soft-client used away from the business location – at a coffee shop or in an airport, or at the employee’s home.
Actually the requirement is the same in all situations – the 911 dispatcher needs to receive the location of the caller – but how this is done can vary for these three situations.
Plumbing
From a technical point of view, there are several pieces of technology that all need to work together to automatically provide the location to the 911 operator:
- The phone soft-client needs to identify its location (at the time of the 911 call), and send that information over SIP using something called PIDF-LO.
- The service provider’s class 5 switch needs to be able to pass this PIDF-LO information to the 911 operator on a SIP trunk.
- The 911 carrier needs to support receiving and processing the PIDF-LO so that it’s usable by the operator.
If you have SIP trunks to a next-gen 911 provider, they should support this technology, and recent versions of the Metaswitch software support passing PIDF-LO through (with some configuration updates) – so the core network plumbing tends not to be the problem.
SIP endpoints
Let’s return to those three different scenarios I mentioned earlier, and see how the SIP endpoint can access the location information.
- A modern cell phone has GPS built-in, making location easier to access. In the case of Max UC Mobile, Metaswitch’s approach is actually to force 911 calls to be placed with the native dialer, thereby avoiding this issue entirely.
- If a phone client moves around within a business location it’s possible, with a bit of effort, for the client to automatically identify its location. Metaswitch has taken an approach where the business group administrator (through CommPortal) can identify certain IP subnets or wireless access points as being in certain dispatchable locations – and then Max UC is able to use that information to identify the device location and pass that along in the SIP messages when a 911 call is made. This is a pretty nice feature, and as a service provider you should be making sure your business customers are aware of this, and are aware that they have the responsibility to create this mapping and keep it up to date. This isn’t particularly easy to use, but for a large business with multiple floors or buildings they’re likely to have an IT department capable of implementing this.
- If a phone client moves off-premise and connects to the internet on public WiFi, there’s not really a way for the phone client to automatically identify its location. I guess some laptops and tablets might have a GPS chip, but that won’t always be the case. Metaswitch’s approach is for Max UC to show a customizable warning banner indicating that the 911 location is not known. In an ideal world, this would then provide a link back to the secure portal we discussed above, so the user can temporarily update their location – but at a minimum, it warns them of the problem.
Test and Communicate
There’s more to Ray Baum than I’ve covered here – check out the FCC’s information or this useful info from Bandwidth to learn more.
The most important things to remember from all this are as follows.
- This is important – to save lives and to comply with the law – so make sure you understand it, and understand what you need to do.
- Test – there are a lot of moving parts here, so once you’ve implemented everything, be sure to test that it all works, from the phones through your core network to the NG911 provider.
- Communicate – a lot of the responsibility for making Ray Baum a success falls on the end-users and the administrators at each business. As a service provider you don’t have the information to be able to handle everything yourself, so you need to communicate clearly to your customer base about what they need to do, and when they need to notify you of changes in their network.
The deadline to implement all this was January 6, 2022, but the technology is constantly evolving, and full compliance may not have been technically possible at that time. So if you still have work to do, don’t panic. Make a plan, and work towards it.
