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New Law Affects Texas Business Phone Systems Dialing 911
Thursday, September 1, 2016 7:00 AM

Credit unions in Texas should check to ensure that users of their telephone system can easily dial 911 in an emergency without first being required to dial a prefix/digit to access an outside line as required by “Kari’s Law,” which becomes effective Sept. 1, 2016. The law was passed after a tragic incident where a child was unable to dial 911 from a hotel room because she didn’t know how to access an outside line.

If not already compliant, Texas credit unions should request a waiver immediately by the waiver deadline of Sept. 1, 2016. One waiver can cover multiple locations and/or multiple phone systems. To request a waiver, please go to texas911.org/karislaw. More information can be found below.

Why is it important for me to comply?
A compliant business is protected from liability from claims allegedly arising as a result of a person attempting to access 911.

Am I Compliant?
If you are not sure, double check with your third-party phone system seller, provider, installer, and/or programmer if you have one. They can help you determine how your system has been programmed. If such information cannot be obtained, please contact your local 911 authority which can be found at www.texas911.org/home/lookup.  Obviously, be careful testing your system as we don’t want “test” 911 calls to bog down the system and interfere with legitimate calls for help!

Guidance
The Commission on State Emergency Communications (CSEC) passed Rule 251.16, Direct Access to 9-1-1 Service which implements new Health and Safety Code Chapter 771A requiring all telephone systems that provide or allow outbound calling to allow for direct dialing of 9-1-1 (no initial digit, prefix, access code to reach an outbound line is permitted). A telephone system, commonly referred to as a multiline telephone system or “MLTS,” refers to a legacy or Internet Protocol system comprised of common control units and interconnected handsets that allow for advanced features such as conference calling and direct inward/outward dialing (see rule for complete definition). 

The primary purpose of the rule is to implement the statutory waiver process under which a business service user (defined in the rule) can obtain a one-year waiver (September 1 – August 31) of the law’s requirements upon the timely submission of an affidavit that (1) the business service user made a good faith attempt to reprogram or replace the telephone system; and (2) that reprogramming/replacing of a non-compliant telephone system would be unduly and unreasonably cost prohibitive.

Additional Notification Required in Some Instances
Kari’s Law also requires an MLTS to be programmed to send notification of a 9-1-1 call to a central location on the site of the facility from where the 9-1-1 call was made, and per rule 251.15, also to an optional additional location. Providing call notification is only required if it can be done without improvements to the MLTS’s hardware. (See FAQs for additional information on notification requirements.)

How to Request a Waiver
If such a telephone system cannot be reprogrammed or replaced to meet the direct access requirement without the user incurring undue and unreasonable costs, a one-year waiver shall be granted upon timely submission of an affidavit (click here for FAQs and details on how to submit the waiver affidavit).

For each telephone handset used with a non-compliant MLTS, an instructional sticker must be placed immediately adjacent to, and optionally on, the handset instructing the user how to access 9-1-1 service. The instructional sticker must be printed in at least 16-point boldface type, in a contrasting color using a font that is easily readable, and be written in English and Spanish.

After a waiver is submitted, a confirmation email will be sent from the agency. You will be notified if the waiver was not timely or not complete. Otherwise, the waiver is considered self-certified until the following September 1, and no separate compliance notice will be sent.

Please note that:

  • This waiver is used statewide for the entire state of Texas.
  • The waiver is good for one year (September 1 to August 31).
  • The request must be submitted before September 1st of each year.

Questions
If you have questions, you may contact CSEC at karislaw@texas911.org.