Monitoring from home - UL 827 questions
- Will a home monitoring plan be required to be UL 827 compliant? Even if we choose not to deploy it?
A remote location (home) based monitoring plan is not required by Standard for UL 827-Central-Station Alarm Services. Proposed par 51.1 states that off-site monitoring shall be permitted under conditions specified, but does not mandate its use.
- Can the staffing minimum be met between the primary and secondary site? Does each have to follow it on a per site basis?
If a primary and secondary site operate as a single monitoring entity, with all signals entering a common queue and all operators pulling from that queue or an automation systems pushing signals to the next available operator regardless of geo-location, then overall operator staffing can be managed dynamically between the two sites. Please note that neither site can be completely unstaffed if infrastructure located at both is required for continuity of the overall monitoring operation.
- Are central station (CS) personnel considered essential? If not, why aren't CS personnel considered essential?
In most North American jurisdictions, CS personnel are considered essential. Please note that in most jurisdictions, social distancing and other health risk mitigations apply to essential workers.
- Was there a consideration of a possible extension to proprietary supervising stations per UL 864-Standard for Control Units and Accessories for Fire Alarm Systems?
This proposal does not address proprietary supervising stations as they are outside the scope of UL 827, the Standard for Central Station Services. UL's Certification of Proprietary Supervising Stations is based on the requirements of Chapter 26 of the National Fire Protection Association (NFPA) 72 which does not reference UL 827.
- Do the operators have to have commercial internet service (instead of residential service)?
The proposal does not prescribe a specific class of internet service provider (ISP) service. It would be the responsibility of station management to understand the bandwidth/service level available to candidates for home-based monitoring assignments and make staffing choices based in part on a candidates ability to contribute to a Standards compliant level of service from the CS to its customers.
- Is there an issue with switching from one managed facility voice network (MFVN) to another type of MFVN? What about switching back and forth between analog to digital formats? If the service is voice over internet protocol (VoIP), how do we prevent losing
It would be the responsibility of station management to understand and control the impact of the described type of switching so as to help assure continued Standards compliance of its operations.
- Please clarify if the return to normal operations can be triggered by the expiration of a governmental declared emergency or recommended guidelines. (My concern relates to when health officials may remove guidelines. It could be years before the health ag
The language of the proposal calls for return to normal operations after the expiration of a governmental emergency declaration or after the expiration of health/safety guidelines related to that emergency. In the current COVID-19 environment, continued governmental call for reopened business to maintain adherence to health/safety guideline compliance results in conditions that inhibit normal operations for many monitoring stations. Therefore, in those cases of inhibited operation, the home-based operator procedures of proposed Sec 51 would still be permitted.
- Is it possible to get a transcript of the meeting?
A recording is available at https://UL.wistia.com/medias/rilmehu8p7
- It appears that the new/potential UL positioning will open up an opportunity for non-UL call centers that comply with the aspects of the in-remote mandates to operate providing they use a UL 827A monitoring center for receivers and automation.
The proposal dated May 22, 2020 includes specific conditions under which off-site monitoring is permitted. A current, active governmental emergency declaration or government issued health and safety guidelines are a prerequisite for applicability of off-site monitoring requirements. Absent a governmental declaration of emergency or governmental declaration of need for health and safety mitigations, off-site monitoring would not be in compliance with UL 827.
- I believe that this language opens the use of non-UL call centers or other commercial location that complies with this Standard. If UL didn't contemplate this, language should be added to accommodate those who may have a solution that includes a non-UL ce
The title of Section 51.3.1 makes it clear that the requirements apply to operators working from their place of residence. If a monitoring station has access to a commercial facility that can accommodate staffing at scale while complying with health/safety guidelines, that facility would be considered a Remote Signal Management Center per par 5.2.48 and subject to the requirements of Section 14 of UL 827.
- I believe that operators that work remotely should be required to sign off on a compliance affidavit that outlines all mandated policy, procedures and restrictions. This should also include a disclaimer that everything in their premise including persona
Technically substantiated suggestions for requirements in addition to those proposed are welcome and can be made via UL's Collaborative Standards Development Process.
- Technically substantiated suggestions for requirements in addition to those proposed are welcome and can be made via UL's Collaborative Standards Development Process.
Technically substantiated suggestions for requirements in addition to those proposed are welcome and can be made via UL's Collaborative Standards Development Process
- How do you address physical attack on a operator protecting a jeweler?
The risk of physical attack on an individual operator handling signals from systems that deliver protective services to a variety of customers of a monitoring station was not specifically addressed in this proposal. Risk based, technically substantiated suggestions for requirements in addition to those proposed are welcome and can be made via UL's Collaborative Standards Development Process.
- Is UL Solutions going to require automation providers to include secure remote functionality?
UL 1981, the Standard for Central Station Automation System Requirements, does not require that such systems must provide external access functionality. UL 1981 does provide requirements for secure connectivity when they do. Automation system providers seeking to meet market demand for secure remote functionality are empowered to do so by UL Standards.
- Does civil unrest meet the criteria without a declaration?
The proposed requirements permit home-based monitoring only during the existence of a government declaration of a) an emergency condition, or b) health and safety mitigations. Civil unrest without a governmental declaration of control measures that inhibits station operation would not be a condition that permits use of home-based operators.
- If the CS does not have 24/7 management monitoring staff, why would remote workers require it?
The proposal represents the consensus of 17 industry representatives who viewed 24/7 management of oversight for home-based operators as being appropriate. Technically substantiated suggestions for a change to the proposal are welcome and can be made via UL's Collaborative Standards Development Process.
- One of my concerns of remote monitoring is the operator abandoning their post right in the middle of a dispatch due to an emergency happening at the home.
Technically substantiated suggestions for a change to the proposal are welcome and can be made via UL's Collaborative Standards Development Process in order to be given formal consideration.
- Has anyone from the insurance industry been involved in this?
The Standards Technical Panel includes members with an insurance background in the category of authorities having jurisdiction (AHJ) or Regulator.
- How will the UL Solutions auditor confirm this during the annual inspection?
Audit procedures are under development at this time. They will be handled by UL Solutions outside the ANSI Standards Development Process.
- Will you need documents from each home operator showing their setups?
Par 51.3.3.2 requires that CS management document all factors that lead to approval of each home-based location. That documentation would need to include evidence supporting compliance with work area conditions specified in par 51.3.3.1. In addition, par 51.3.3.4 requires the security architecture of remote operator solutions be documented and made part of business continuity plans.
- Will there be consideration of central monitoring stations to be able to keep this as a permanent situation? With all of the modern workforce being able to work remotely, there are financial considerations.
This proposal only considers use of home-based monitoring agents when an active government declaration of emergency or need to follow health/safety guidelines is in place. Use of home-based operators on a "permanent" basis would require that a separate, technically substantiated proposal be made.
- Reflection on the triggering events including that the following conditions be met, infers, as confirmed by the preclude statement, for redundant sites, unduly limits load sharing, under workforce fluctuations. Shouldn’t we have the flexibility of our ful
This proposal only considers use of home-based monitoring agents when an active government declaration of emergency or need to follow health/safety guidelines is in place. Use of home-based operators on a "permanent" basis would require that a separate, technically substantiated proposal be made.
- Has UL Solutions received any medical guidance on the safety of UL Listed CS continuing to operate during COVID 19 under CDC guidelines?
Input for the proposal came from members of the task group chartered by Standards Technical Panel members. Those members were largely from operating CS that deal with medical safety guidance on a daily basis.
- Does this proposal take into consideration Notice to All Monitored Subscribers so they can make informed decisions between UL Listed CS monitoring and home monitoring?
The proposal dated May 22, 2020 and reviewed in total during the Town Hall event does not include a notice of the type described. Technically substantiated suggestions for a change to the proposal are welcome and can be made via UL's Collaborative Standards Development Process.
- Liability is a factor that no one can eliminate when performing UL Listed CS monitoring. What, if any, analysis is being performed to address liability as it relates to home monitoring?
This proposal is being developed and handled administratively in compliance with the American National Standards Institute (ANSI) balanced committee, continuous development process requirements. Compliance with the American National Standard for Central Station Services can be an indicator of due diligence on the part of a monitoring station.
- If an authority having jurisdiction (AHJ) determines that home monitoring is not acceptable for commercial fire by way of example, how would that be handled?
From a purely Standards perspective, CS serving customers in jurisdictions where the authority does not accept home-based monitoring could make arrangements for signals from that jurisdiction to be routed to station-based operators for handling, or make a business decision to exit that market.
From a market perspective, with sufficient stakeholder/constituent demand, third party certifiers could potentially develop new offerings tailored to meet the needs of those managing specific risks.
- How can this proposal protect against someone other than the home operator taking a cell phone photo of the subscriber screen? What if a un-qualified person views the monitoring system?
Par 51.3.3.1 requires that the work area be such that unauthorized viewing of the monitoring screen is prevented. If a person other than the operator is able to view the monitoring screen, the workplace arrangement would not comply with the proposed language.
Next Steps for proposed revisions to UL 827
The UL 827 task group will meet to review all comments. If there are changes to the proposal based on those comments, changes will be posted in UL's Collaborative Standards Development System (CSDS) as part of Recirculation. Responses to all comments received during the Ballot public review will also be posted. For any standard related questions, please contact Wathma Jayathilake.
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