sundance-communications.com Forums General General Telephone & Systems Information Kari's Law & Ray Baum's Act as pertaining to Business Telephones

There have been many posts in this and other Forums regarding Kari's Law & Ray Baum's Act and what it means.


Compliance date (MLTS direct dialing and notification) and Exemption for Legacy MLTS: Kari’s Law and the Commission’s rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020. (See 47 CFR § 9.17(b).)

All other MLTS (i.e., systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020) must meet the following compliance date:

Feb. 17, 2020:*

MLTS manufacturers, importers, sellers, and lessors:

May not manufacture or import for use in the United States, or sell or lease or offer to sell or lease in the United States, an MLTS, unless the system is pre-configured so that when it is properly installed in accordance with the MLTS rules, a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for the other calls. (47 CFR § 9.16(a)(1).)
MLTS installers, managers, and operators:

May not install, manage, or operate for use in the United States an MLTS, unless the system is configured so that a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9, regardless of whether the user is required to dial such a digit, code, prefix, or post-fix for other calls. (47 CFR § 9.16(b)(1).)

Shall, in installing, managing, or operating an MLTS for use in the United States, configure the system to provide MLTS notification to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system. (47 CFR § 9.16(b)(2).) MLTS notification must meet the following requirements:

• It must be initiated contemporaneously with the 911 call, provided that it is technically feasible to do so; and
• It must not delay the call to 911; and
• It must be sent to a location where someone is likely to see or hear it. (47 CFR § 9.16(b)(2).)

For more information read: FCC Title 47 / Chapter 1 /Sub-chapt...notification, and dispatchable location.


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I think the part that confuses people is:



That wording throws out the exemption for legacy systems. It's not clear that it is implied that they may not manage or operate a system that does not comply only if was manufactured or installed after February 17, 2020.

Idiot lawyers!

-Hal

"Kari’s Law ...do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020."

So after that date "first sale or lease, first sold or leased, or installed after February 16, 2020." As long at the MLTS manufacture has their act together software-wise for NEW systems.

Legacy rules still apply if installation was before February 16, 2020.