TDI Editor’s Note:
The FCC recently issued an Enforcement Advisory that reminds VRS and other Internet-based TRS providers of their obligations in processing emergency calls. Below is an adaptation of the Advisory from TDI so consumers can know what to expect in case they need to make an emergency call through any Internet-based relay services, including video relay.
FCC Reminds Internet-Based Telecommunications Relay Service Providers of Emergency Calling Requirements
In 2008, the Federal Communications Commission (FCC) announced new rules regarding emergency call handling requirements for providers of video relay services (VRS) and other Internet-based Telecommunications Relay Services (TRS) such as Internet Protocol relay (IP relay) on a web browser or through a commercial instant messaging service like AIM or Google Chat. The reason for these requirements is to ensure that people with hearing or speech disabilities who use Internet-based TRS have access to 9-1-1 service that is comparable to what is available to TRS users on the traditional telephone network. If an Internet-based TRS provider fails to complete an emergency call properly, which includes passing on information that identifies your current location to the appropriate emergency services, there could be some risks to public safety. Because of these potential risks that would result, the Enforcement Bureau at the FCC issued an Enforcement Advisory to remind VRS and other IP relay providers of these requirements. These 9-1-1 emergency call-handling requirements apply regardless of which equipment or software you use when you seek emergency assistance through the relay on the Internet-based TRS.
The 911 emergency call handling rules for IP Relay and VRS providers include, among other things, the following requirements:
- IP relay and VRS providers must transmit all 9-1-1 calls – including your ten-digit phone number (called automatic number identification or ANI), your registered location, the name of the VRS or Internet-based TRS provider that you use to make the call, and the video interpreter or communications assistant’s (CA’s) identification number for the call — to the public safety answering point (PSAP) or other appropriate local emergency service for the caller’s registered location;
- IP relay and VRS providers must prioritize all incoming emergency calls and move them to the top of the list so they are answered before any non-emergency call;
- IP relay and VRS providers must route all 9-1-1 calls based on your ten-digit number through the dedicated wireline E9-1-1 network to the PSAP, or appropriate local emergency authority that serves the caller’s registered location;
- If the VRS or Internet-based TRS is capable of being used from more than one location such as laptop computer or other wireless device, the IP relay or VRS provider must offer you a way to update your registered location instantly at anytime on the device you use to access the VRS or Internet-based TRS;
- If one or both sides of the emergency call (i.e., either between you and the relay service and/or between the relay service and the emergency service) is disconnected, the IP relay or VRS provider must immediately re-establish contact with you and/or the appropriate emergency service.
All VRS and other Internet-based TRS providers must follow these emergency-calling requirements regardless of the equipment or software you use to call on the relay. This means that when you make a 9-1-1 emergency call through VRS or other Internet-based TRS using customized equipment and software provided by the TRS provider and/or any off-the-shelf hardware and software that might come from a different source, the VRS or Internet-based TRS providers must fully comply with the FCC’s emergency calling requirements or become ineligible for compensation from the interstate TRS Fund. In addition, any violation of these requirements may also subject the VRS or Internet-based TRS provider to severe monetary penalties.
For additional consumer information on emergency calling requirements for VRS and Internet-based TRS providers, please contact Diane Mason of the Consumer & Governmental Affairs Bureau’s Disability Rights Office at 202-418-7126 or firstname.lastname@example.org. You may also call the FCC on the TTY at 1-888-Tell-FCC (1-888-835-5322) to learn more about the emergency calling requirements for Internet-based TRS providers.
To request materials in alternative accessible formats for people with disabilities (Braille, large print, electronic files, audio format), send an email to email@example.com or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY).
Adapted by TDI:
From FCC Enforcement Advisory #2011-05
Issued on February 16, 2011 (DA 11-304)
– Thanks to TDI (2/25/11)