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Are you ready to comply with Michigan’s MLTS E911 legislation?

October 1, 2019 Article 4 min read
Matthew Lindner
Michigan’s new regulations for multiline telephone systems and emergency calls go into effect in 2020. With varying deadlines, requirements, and exemptions, compliance may be complex. We break down the key aspects for you.
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Michigan’s long journey toward more stringent legislation on enhanced 911 (E911) emergency calls is nearing completion. With the adoption of Public Act 30 of 2019 on June 25, 2019, organizations operating Multi-Line Telephone Systems (MLTS) now have information on compliance requirements, and when they must comply. The new regulations are complex and loaded with varying deadlines, definitions, and exemptions. So what do you need to know to ensure that your organization can comply in a timely manner? We unpack the new regulations to give you some clarity.

A little background

The intent of the new regulations is to provide emergency responders with more specific location information than a simple address in case they’re responding to a call at a large facility. The regulations will apply to any “workspace” larger than 7,000 square feet with a compliance deadline of Dec. 31, 2020; a workspace is defined as the physical building area where work is normally performed, measured by net square footage. The originally proposed legislation included any facility with an area greater than 7,000 square feet, but the enacted version more clearly defines those spaces within a facility that must be considered.

  • A workspace includes: offices, production areas, warehouses, and shop floors; storage areas; hallways; conference rooms; and break rooms and other common areas.
  • A workspace does not include: wall thickness; shafts; heating, ventilation, or air conditioning equipment spaces; mechanical or electrical spaces, or any similar areas where employees don’t normally have access.

The regulations will apply to any “workspace” larger than 7,000 square feet with a compliance deadline of Dec. 31, 2020.

What specific location information must be reported?

The answer varies, depending on certain aspects of the facility in question as detailed below. Generally, it’s defined within the legislation as a location to which a 911 emergency response team may be dispatched, and the caller quickly located, that’s not more than 7,000 square feet as identified by:

  • Room or unit number
  • Room name
  • Equivalent unique designation of a portion of a structure/building

What must be reported?

When facilities with only a single building are considered, reporting requirements are fairly straightforward. The only variable to consider is the number of floors in the building. In all instances, the street address and specific location of the communications device must be reported. Facilities with multiple floors must additionally report the building floor number. Note that these apply to single buildings with over 7,000 square feet of workspace, with their own street address on a single contiguous property.

When facilities with multiple buildings served by the same MLTS are considered, similar requirements apply with some additional complexity. The MLTS must systematically report the street address (including unique address if there are difference addresses for each building), unique building identifier, and specific location of the communications device. Building floor numbers must also be reported for any structure with multiple floors.

E911 exemptions

The regulations allow for certain specific exemptions to the requirements detailed above:

  • If a building contains less than 20,000 square feet of workspace and less than 20 communications devices, the MLTS operator is exempt from providing specific location information until it installs a new MLTS after Jan. 1, 2020.
  • If a building maintains, on a 24-hour basis, an alternative system capable of identifying the location of any communications device that dialed 911 or the building is serviced with its own appropriate medical, fire, and security personnel, it’s exempt.
  • Any MLTS operator that’s not currently served by enhanced 911 service is exempt until enhanced 911 service becomes available.
  • Other exemptions exist for farms and houses of worship, which, for the latter, doesn’t extend to attached schools.

What about Kari’s Law?

While not necessarily a component of the Michigan regulations, Kari’s Law is a federal regulation that must be considered as well. Any MLTS equipment that’s manufactured, imported, sold, leased, or installed after Feb. 16, 2020, must be capable of enabling its users to dial 911 directly without having to dial a prefix.

E911: Key implementation considerations

If you operate in a facility that’s subject to these regulations, planning for compliance can be very challenging.

  • How do you effectively identify and map specific locations at your buildings? Ask yourself, “If a caller on the MLTS couldn’t speak, would an emergency responder be able to find them based on the information the system automatically provides?”
  • How do you know if your existing MLTS can support the new requirements? If you need a new system as a result of the legislation, what’s the right way to identify system that best meets my organization’s needs?

“If a caller on the MLTS couldn’t speak, would an emergency responder be able to find them based on the information the system automatically provides?” 

For additional implementation questions or assistance, please contact our technology consulting team today.

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