Updated March 16, 2022
- What is “TRS”?
- 911 Call Processing
- Information Privacy
- Disclaimer of 911 Liability
What is “TRS”?
The Federal Communications Commission (“FCC”) defines Telecommunications Relay Services (“TRS”) as the service which allows persons who are deaf, hard of hearing, deaf-blind, or have speech difficulties to communicate with one or more individuals through the use of telecommunications equipment/services, otherwise known as “phone calls” or “calls”, in a manner that is functionally equivalent to calls placed or received by persons who do not have hearing or speech difficulties. Under Title IV of the Americans with Disabilities Act, as amended, the FCC must ensure the provision of TRS. TRS is available in all 50 states, the District of Columbia, Puerto Rico, and all other U.S. territories for local, long distance, and international calls.
911 Call Processing:
Telecommunications Relay Services have evolved over time and a variety of devices are available to facilitate a TRS telephone call. Some devices use the Public Switched Telephone Network (“PSTN”; aka “landline”) to carry the telephone call while others use alternative transmission methods such as Voice-over-Internet Protocol (“VoIP”). Some connect to the Relay service over the PSTN, while others have an internet connection for receiving captions. Depending on the service and/or system used, 911 calls are handled differently. We strongly recommend that You use Your landline telephone service or Your native mobile phone service to call 911 directly for a faster connection in the event an emergency.
I. Traditional Relay Services
If You place a 911 call through 711 relay using a TTY, Your emergency call will be routed to an appropriate public safety answering point (“PSAP”) based on the area code and prefix of Your telephone number, and Your telephone number and address registered to that phone number will be made available to the PSAP. The Relay Operator/Communication Assist will be available to relay the conversation as needed during the call. We strongly recommend that You dial 911 directly from Your TTY device for faster connection in the event of an emergency.
II. Captioned Telephone Service
1-Line CapTel Phones (Models 200, 800, 840)
911 calls placed using 1-line CapTel phones will be routed the same way that Your underlying voice service provider routes traditional telephone calls. For example, if You place a 911 call using a 1-line CapTel phone connected to a PSTN landline, the call will be routed to an appropriate PSAP. You must consult Your underlying voice service provider for details regarding how 911 calls are routed for Your voice service, including how the PSAP will receive Your call-back number and location information.
911 calls placed with 1-line CapTel phones are directly connected to the PSAP without first routing through the Captioning Service, so these 911 calls are not captioned in the same manner as non-911 CapTel calls. You will, however, be able to speak directly into the handset, as You would with any other CapTel call, and the 911 call-taker will hear everything You say. You may not be able to hear the call-taker, but if You are using a PSTN landline the call-taker may be able to type instructions to You, which will appear on the CapTel display screen.
2-Line CapTel Phones (Models 800 2-Line, 840 2-Line, 200 2-line)
911 calls placed using 2-line CapTel phones will be routed the same way that Your underlying voice service provider routes traditional telephone calls. You must consult Your underlying voice service provider for details regarding how 911 calls are routed for Your voice service, including how the PSAP will receive Your call-back number and location information.
If You are using a PSTN landline, the 911 call will be captioned as normal if captions are turned “ON” on Your phone. Captions may not work if You are using VoIP or some other form of voice service.
Internet-Based (IP) CapTel Phones (Models 2400i, 880i, 840i, 800i)
911 calls placed using IP CapTel phones will be routed the same way that Your underlying voice service provider routes traditional telephone calls. You must consult Your underlying voice service provider for details regarding how 911 calls are routed for Your voice service, including how the PSAP will receive Your call-back number and location information.
Although an internet-based CapTel phone connects to the Captioning Service over the internet, the telephone call is still processed through Your underlying voice service provider. You will get captions of the call directly from the captioning service if captions are turned “ON” on Your phone and internet service is available.
Hamilton® CapTel® for Business, Interconnected by Tenacity™
The Hamilton CapTel for Business, Interconnected by Tenacity solution is currently available on Cisco business phone systems. Please refer to Your Telecom Administrator to learn how to dial 911 on Your Cisco phone system. The setup in Your business’ phone system will determine how Your call is routed and there may be specific steps You must take in order to process an emergency call with the Cisco phone.
When You dial 911 using Your Cisco phone, You may be connected directly to an appropriate PSAP, as configured on the Cisco Unified Communications Manager (“CUCM”) by Your Telecom Administrator. The captions on the call will be connected to the Hamilton CapTel Call Center as long as You are logged in to Your Hamilton CapTel account, have elected to turn captions “ON,” and have a working internet connection. If at any time during a 911 CapTel phone call You elect to turn captions “OFF”, You will not receive captions until You turn the captions feature back “ON”.
Hamilton Mobile™ CapTel® & Hamilton Web CapTel
911 calls made using Hamilton web and mobile CapTel apps are processed outside of the PSTN and rely on the internet to connect to the captioning service and connect the audio call. Information provided by You is used to properly route and connect the 911 call and locate You in an emergency. If You choose to use the Hamilton Mobile CapTel App or Hamilton Web CapTel to place a 911 call, there are limitations and possible delays.
Relay App Services handle 911 calling differently than traditional telephone services. Using traditional telephone services is the fastest way to call 911, as Your telephone or TTY provide a direct link to Your emergency service provider. In contrast, Relay App Services do not provide a direct link to the emergency service provider; therefore it is important that You provide Your location information to the 911 center at the beginning of the call in order to transmit Your physical location to an emergency center. It may not be technically feasible to transmit automated dispatchable location to Your emergency provider. Hamilton recommends that You enable location services on Your web and mobile devices, if feasible.
Hamilton is required to transmit 911 emergency calls made through the Relay App Services in accordance with federal law and policies. As part of this requirement, and in order to transmit important information to emergency service providers, Your name, number, and location may be requested at the beginning of an emergency call. If You call 911 using a web or mobile device and Hamilton is not able to identify Your current location, Hamilton may transmit Your phone number and registered address to the local emergency center serving the location of Your registered address. Please note the call may not be routed to an appropriate Emergency Service Provider or Public Service Answering Point if You are in a location other than Your registered location.
If You do not or cannot provide current location information, Your call may not be routed to an appropriate Emergency Service Provider or PSAP.
If Hamilton’s mobile or web apps do not support the operating system or browser on Your computer or mobile device, You will not be able to use the service to place any calls, including 911 calls. Please review the technical recommendations for each product in the FAQs and contact Hamilton CapTel Customer Care if You have questions about the compatibility of Your system with Hamilton CapTel.
IF THE PHONE, COMPUTER OR MODEM USED TO ACCESS THE INTERNET DOES NOT HAVE A BACKUP POWER SOURCE, THE SERVICE WILL NOT WORK AT ANY POINT THE PHONE, COMPUTER OR MODEM IS NOT PLUGGED INTO A POWER OUTLET OR AT ANY POINT THAT POWER OUTLET IS NOT RECEIVING ELECTRICITY (FOR ANY REASON, INCLUDING A UTILITY POWER OUTAGE). HAMILTON RELAY RECOMMENDS THAT YOU MAINTAIN A LANDLINE FOR EMERGENCY CALLS. HAMILTON RELAY CANNOT ASSURE THE FOLLOWING WHEN MAKING A 911 CALL USING WEB AND MOBILE SERVICES: (1) A CONNECTION WILL BE ESTABLISHED; (2) THAT YOUR CORRECT LOCATION WILL BE ELECTRONICALLY AVAILABLE TO THE EMERGENCY SERVICE PROVIDER; OR (3) THAT CAPTIONING SERVICES WILL NOT SLOW THE RESPONSE TIME OR THE RELAY OF EMERGENCY INFORMATION.
Emergency calling through the Service is available only for calls placed from a location within the United States or one of its territories or possessions. VOICE OVER IP (“VOIP”), WEB, AND MOBILE CAPTEL EMERGENCY CALLS ARE NOT THE SAME AS TRADITIONAL TELEPHONE OR TTY EMERGENCY CALLS. IN AN EMERGENCY, HAMILTON RECOMMENDS THAT YOU USE A TELEPHONE OR TTY IF POSSIBLE TO MAKE AN EMERGENCY CALL IN ORDER TO CONNECT YOU DIRECTLY WITH EMERGENCY OFFICIALS. WHEN MAKING A VOIP, WEB, OR MOBILE CAPTEL EMERGENCY CALL, HAMILTON MAY NOT AUTOMATICALLY BE ABLE TO OBTAIN YOUR PHYSICAL LOCATION INFORMATION IF IT IS DIFFERENT THAN YOUR REGISTERED LOCATION INFORMATION, OR ROUTE YOUR CALL TO APPROPRIATE EMERGENCY PERSONNEL.
All information obtained as a result of the above-described processes is limited to that needed to facilitate 911 services and is made available only to emergency call handlers and emergency response or law enforcement personnel. All information is used for the sole purpose of ascertaining Your location in an emergency situation or for other emergency or law enforcement purposes.
Disclaimer of 911 Liability
As a provider of relay services and as a provider of emergency communications for purposes of the Federal NET 911 Act, Hamilton asserts immunity and other protection from liability under both state and federal law in connection with its provision of 911 dialing service. In addition, Hamilton disclaims all responsibility for the conduct of local emergency response centers and the national emergency calling center. Hamilton does not have any control over any local emergency response center or the national emergency calling center. Therefore, Hamilton is not responsible for whether those centers answer calls made using Hamilton’s 911 dialing service, how they answer such calls, or how they handle them. Hamilton relies on third parties to assist in routing 911 dialing calls to local emergency response centers and/or, to the extent permissible under federal law, to a national emergency calling center. Hamilton cannot ensure that Your local emergency service provider is capable of handling all 911 calls. Accordingly, Hamilton is neither liable nor responsible if the data used by a third party to route such calls is incorrect or produces an erroneous result. Neither Hamilton nor its officers, directors, shareholders, employees, agents or subcontractors may be held liable for any claim, damage, loss, fine, penalty, cost, and/or expense (including, without limitation, any and all attorneys’ fees) by, or on behalf of, any Hamilton customer or any third party or user of Hamilton’s Service, relating to or arising out of Hamilton’s Service, including, without limitation, 911 dialing, or any device used in connection with Hamilton’s Service.