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.
The options for providing 999 access are: via a direct line; or via a workplace phone system (ie PBX).
A direct line would be the most appropriate means of access in small premises, but in larger premises, where it would be impractical and costly to provide direct lines for easy access throughout the premises, it would be more usual to provide 999 access via the PBX.
If there is a PBX then 999 access should be provided via the PBX extensions even if there are direct line emergency phones available. There is no specific legislation on this, but if 999 calls are barred on a PBX and this causes a fatal delay in the emergency response then the organisation can expect to face action under Health & Safety legislation.
There is an obligation under Health & Safety legislation for organisations to carry out a regular risk assessments and take steps to minimise any risks that are identified. Barring 999 access from a PBX is analogous to barring access to a fire exit.
There is also an Ofcom Code of Practice for PBXs which states that 999 calls can only be barred if there is a satisfactory permanently manned alternative on the organisation’s premises. The Ofcom Code of Practice includes some examples of where a private emergency response solution would be appropriate:
- organisations dealing in hazardous substances where specialist units or precautions from the Public Emergency services may be required;
- organisations with their own Emergency services (e.g. Airports etc.); or
- organisations subject to a high degree of hoax calls (e.g. Colleges, Hotels).
In the absence of any specific telecommunications legislation on 999 calling from PBX phone systems the Ofcom Code of Practice is the only reference that is available for organisations when planning for 999 access from their PBX. If organisations follow the guidelines i the Code of Practice they can be confident that they are meeting their legal obligations associated with 999 calling.
In addition to providing 999 access from PBXs the Ofcom Code of Practice makes it clear that organisations should ensure that the location information that is delivered with a 999 call from their PBX is accurate and reliable. This is a legal requirement for 999 calls made from direct lines that was introduced to provide protection for 999 callers that could not provide verbal confirmation of their location. This may be the case if the caller is:
- unable to speak (eg due to smoke inhalation or physical danger); or
- does not speak English, or has a strong dialect, or speech impairment; or is
- unaware of their precise location, or is disoriented.
Ensuring that the correct location information is delivered with a 999 call from a PBX is not a simple task for organisations with large premises or with PBXs that serve multiple sites.
For large premises (eg multi-floor & multi-wing office blocks, campuses, or dispersed factory sites) the problem is that the location information presented to the 999 operator is that of the site address. This may not be sufficiently granular and additional systems may be required to ensure that when the emergency services arrive at the site reception desk the receptionist, first of all, knows that a 999 call has been made and has access to internal systems that will enable the precise location of the caller to be identified.
For multi-site PBX networks the problem is that the location information presented to the 999 operator may be completely wrong. For example, a 999 call made in the Manchester office may leave the PBX network at the London office and as a result the 999 operator will be presented with the London office address. This is obviously not good!
The Ofcom Code of Practice for PBXs specifically states that PBX networks should be designed in such a way that the correct location information is presented to the 999 operator.
With the previous generation of PBXs that used a technology known as TDM or analogue it was relatively easy to design PBXs to comply with the Ofcom 999 Code of Practice. However, it is not so easy to comply with the Code of Practice with the latest PBXs that are based on IP technology).
With IP-PBXs it is not straightforward to establish the location of the 999 caller since the caller can be at any site on the network with their soft-phone or wireless phone and can keep the same extension number. In other words extension numbers are no longer a valid indication of the caller’s location.
Ofcom have made it clear that the Network Code of Practice is still in effect. This means that organisations must ensure that their PBXs comply with the Code of Practice in terms of 999 access.
There are solutions available that will ensure that an organisation’s multi-site IP-PBX network complies of the Ofcom Code of Practice. These are available from ConneXon of North America who are market leaders in 911 calling solutions for PBXs and have launched their products in the UK under the brand name E999.
For more information on 999 calling obligations, E999 and ConneXon you should complete the contact form below.
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