What are my obligations for providing 999 access in the workplace?


It is now the norm that large private telephone networks serving multiple sites use VoIP technology and are based on an IP-PBX server. The sites that are served by a multi-site IP-PBX telephone network can range in size from single person home-offices to premises with thousands of employees.

Each site would be connected to the central IP-PBX server by an internet VPN. In larger networks there may be more than one PBX server to provide redundancy.

IP-PBX based private telephone networks have many advantages in terms of cost-saving and operational flexibility compared to their TDM and analogue predecessors, but they are at significant disadvantage in terms of providing reliable location information for emergency calls that originate within the network.

Ironically, it is the cost-saving opportunities offered by centralised PSTN breakout together with the flexibility of extension mobility that are the root cause of the caller location identification problems on multi-site IP-PBX networks.

The reason that the automatic provision of reliable location information is important is to cater for emergency situations where the caller is:

  • unable to speak;
  • disoriented; or
  • has difficulty making themselves understood due to language or dialect issues.

Emergency Caller Location Identification Solutions

If the requirement is for location identification that is as granular as the site address then it is possible to solve these problems by deploying a dedicated emergency call routing service.

However, if greater granularity is required (eg to floor or room location) then it would be necessary to deploy an IP-PBX vendor add-ons such as the Cisco Emergency Responder or third-party add-ons such as the ConneXon Emergency Gateway.

Typically such add-ons would track extension users by their IP address or the switch port to which their phone is connected. In an IP-PBX network this is a significantly more reliable indicator than the extension number of the user.

Despite the availability of solutions to the problem of location identification our experience is that many organisations turn a blind eye to this issue and continue to deliver misleading location information with 999 or 112 emergency calls that originate within their private telephone network.

We consider below the regulatory, legal and moral obligations for deploying one of the available solutions that would ensure that accurate and precise location information is presented to the 999 operator (or even an internal safety desk) when an emergency call is made from within a private IP-PBX telephone network.

Regulatory obligations

The telecommunications regulations that cover 999 calls are contained in Ofcom’s General Condition 4 which is in turn derived from Article 26 of the European Framework Directive for Electronic Communications.

Ofcom’s current view is that there are no regulatory obligations that require an organisation to provide 999 access from their private telephone network and therefore there is no requirement to provide accurate location information for 999 calls.

However, there are guidelines published by the European Telecommunications Standards Institute (ETSI TR 102 180) which contain recommendations on how Article 26 should be implemented. Although Article 26 does not have any specific regulatory obligations for private telephone network, the ETSI guidelines do address this issue.

In particular ETSI TR 102 180 states that:

“Location information within a private network should be made available when possible and comply with the requirements of the corresponding emergency authorities in the country/area, in which the site or premises of the company are installed”

and that

“with the development of large corporate networks, it may not be sufficient to estimate the location of the caller with the location of the connexion to the public network. To maintain the accuracy of the location information of the caller the corporate network should provide a location information and transmit it to the public transport network.”

In summary, there are no specific regulatory obligations that apply to an organisation with a private telephone network requiring that emergency calls are delivered with accurate and precise location information.

However, there are guidelines and recommendations from the main European Telecommunications Standards body that require private telephone networks to be designed such that they deliver reliable location information for emergency calls.

In the longer term it is likely that the next EU Directive covering telecommunications regulations will include amendments to the 999 and 112 calling obligations that make it clear that these obligation also cover private telephone networks.

Incidentally, Ofcom have stated that private telephone networks rented from third parties (ie hosted networks) are in fact covered by the regulatory obligations of General Condition 4.

This throws up the bizarre situation that the regulatory protection available to an end-user of a private telephone network depends on how the network is financed!

Legal obligations

The only legal obligation for the provision of 999 access in the workplace is that employees and visitors to workplace premises must have access to a phone that can be used to call the emergency services.

This is an obligation under Health & Safety legislation.

A direct PSTN line would be the most appropriate means of providing 999 access in small premises, but in larger premises, in which it would be impractical and costly to provide direct lines at strategic points throughout the premises, it would be more usual to provide 999 access via the workplace telephone system.

In larger premises the issue with the location information associated with a 999 call would be whether the location information is sufficiently precise to enable rapid assistance for the person is distress. This could be an issue in multi-floor offices, factory premises or campus sites.

The issue for multi-site private telephone networks is whether the location information is accurate.

In both cases there is the possibility that the location information is not fit for purpose. It therefore represents a risk for employees and visitors to an organisation’s premises.

Although there is no specific legislation that addresses the issue of location information associated with 999 calls, the Health & Safety Act does contain legal obligations requiring employers to minimise risk at the workplace. There is also an obligation to undertake regular risk assessments and take reasonable steps to minimise any risks that have been identified.

There is clearly an identifiable risk associated with a private telephone network that delivers misleading location information with a 999 call. For example, the emergency authorities could be sent to the wrong office, or they could spend time waiting for a person in distress to be located in a large campus or factory site.

The obvious risk is that the resultant delays would cause the person in distress to be subject to additional distress with possibly significant adverse consequences due to delayed treatment.

Once this risk has been identified doing nothing is not an option. Health & Safety legislation requires that reasonable steps are taken to minimise this risk.

The other legal issue that should be considered in this context is that of Corporate Liability.

Here the issue is that the organisation may be sued if someone suffers, or even dies, because the emergency services are delayed due to misleading location information being delivered by the private telephone network when that person made a 999 call.

It would be very difficult to defend such a lawsuit if there are obvious steps that could be taken to ensure that precise and accurate location information is delivered with the 999 call.

The person(s) that design and manage an organisation’s private telephone network should be aware of the ETSI recommendations and the availability of the various solutions to the problem of 999 caller location identification.

Moral obligations

Irrespective of the regulatory and legal obligations discussed above, all organisations have a moral duty of care to provide maximum protection for their workforce and visitors to their premises.

Therefore, ensuring that precise and accurate location information is delivered with a 999 call from their private telephone network is simply the right thing for an organisation to do.

Doing the right thing ensures that anyone in their workforce who is in the unfortunate situation of having to make an emergency call would receive the necessary assistance as quickly as possible.

Get in touch with Premitel if you have a specific requirement or if you wish to discuss how your business could make better and more cost-effective use of its existing telecommunications and internet infrastructure and services.