Changing our 999 routing policy

Simon Woodhead

Simon Woodhead

25th July 2022

By Simon Woodhead

As a wholesale / carrier services provider, we offer 999 call routing and the ability to update the Emergency Handling Agency’s database for all Simwood numbers and numbers ported to us, as well as the millions of numbers we host for other networks where the network delegates that to us. Ultimately though, Ofcom are very clear in the General Conditions that the responsibility for your end users being able to complete these calls is yours not ours, i.e. it is your responsibility to procure this service, and you can procure it from us. 

Over the years we’ve been concerned at the providers who appear to have no 999 provision whatsoever, and thus their end users being unable to seek emergency assistance, and them not being compliant with the rules they operate under. We’ve addressed this numerous ways, making our service progressively more commercially accessible and for the last several years completely free to set-up. That is to say: you need to pass our testing to have it enabled on the account, having requested us to do so of course, but we fully subsidise the cost of doing so, so nobody has any excuse for not complying with their responsibilities and denying their users potentially life-saving help.

Some customers have done more as a result of that, i.e. done the free testing and passing calls, but fail to ever update the EHA database. This is an issue as in the event of no database entry, help potentially doesn’t know where to go and administratively all hell breaks loose when this happens. Others route all 999 through to us regardless of which operator the number belongs to. That is also a problem as there may or may not be an entry in the EHA database and BT in particular get very stroppy with us about what they call their number being used for calls over our network, and threaten little short of armageddon if we don’t stop such calls. When challenged they won’t actually ask us to block the calls for life-saving help but the entire dance is time consuming and tedious. As a result, for some time we’ve levied a charge where a call is passed which does not have details updated in our 999 database to contribute to the cost of both scenarios. 

We raised these issues with Ofcom last year and we’re pleased to see they’re now asking questions of CPs around their compliance. However, the immediate consequence of that seems to be a significant increase in attempted calls over the network for providers who are not enabled for 999 service and thus who have not updated the EHA database. They have clearly just added 999 routing to tick a box for Ofcom even though those calls cannot complete.

Naturally, we have full data on who passed testing when, and indeed who has attempted calls for which service wasn’t enabled. Ofcom have requested this previously, and may well do so again. None of that, or indeed any resulting fine, benefit the person needing help however!

Thus, effective August 1st we will be changing our policy yet again. From that date, we will complete all authenticated calls over the network to 999 regardless of whether the account is established for service or not, and whether EHA data has been updated or not. This ensures that however reckless their operator is, presuming they are doing the bare minimum of routing 999 to us, the person seeking help will be connected to it.

As well as the aforementioned charge for enquiries where no details exist, or the number isn’t in our database, the call charges we levy for connecting 999 calls (at wholesale: remember, they must be free to your customers) will now be tiered. The long-published rates will apply to those who are service-established whilst those who would previously have seen calls rejected will now see a higher rate applied to cover the costs of the Simwood team dealing with the (well deserved) grief from BT, Ofcom, the Emergency Services, Government departments and the kitchen sink created by their failures to comply with the basic rules for 999. 

Remember too, that if your platform has only one point of interconnect with us, and you have no secondary route to another carrier for 999, regardless of how much of our service establishment you do and how perfect your address data is, you are still not compliant. The regulations require no single point of failure – that means you need to have two diverse routes. We’d like to think it is two separate Simwood Availability Zones, but, given we’re talking about people’s lives here when they need help the most, we really don’t care who the second is, providing you have it. 

The rate will be published ahead of August 1st but, frankly, if you have to ask what it is rather than undertake testing that we pay for, I wouldn’t have many polite words in reply. I also strongly suggest you audit your 999 routing and processes before the 1st of August, because if the Emergency Services are answering calls that are just your users trying to listen to voicemail or dial an outside line, you’ll have plod on your doorstep. 

Again, to enable wholesale accounts for 999 service, please contact our team to undertake testing with us and they will be very happy to help. It is not permissible for you to make random unscheduled calls to 999 by way of testing at any time however, for hopefully obvious reasons! There is a very specific process to follow, which is part of that free (!) establishment we offer. 

Finally, I would like to thank our many wholesale customers that take their obligations seriously and about whom we’ve never had a single complaint. It is a shame that operators at all levels don’t have to publish a hygiene score on the door like food establishments (mandatory in Wales and NI)!

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