SOC Revision

APCO filed formal comments as part of the SOC revision process, suggesting two changes:

1.   Use the title, “Public Safety Telecommunicators” (instead of “dispatchers”.)

• “Public Safety Telecommunicators” better encompasses both 9-1-1 call taking and emergency dispatch, and aligns with the Congressional Resolution that established National Public Safety Telecommunicators Week.

2.   Classify them as a “protective” occupation, in the same category as police officers, firefighters, lifeguards, crossing guards, and TSA screeners (instead of with clerks and secretaries) because Public Safety Telecommunicators:

• Coach 9-1-1 callers through first aid.
• Coordinate police, fire, and EMS to keep them and the public safe.
• Operate specialized systems for tracking field responders, locating 9-1-1 callers, and communicating in emergencies.
• Deal with the stress of life or death situations. If a Public Safety Telecommunicator makes a mistake, it can cost lives. Members of the public might not get the help they need, and first responders might walk into a trap or might not receive the help they need.

The revised detailed occupation name and categorization of the SOC would look like this:

33-0000 Protective Service Occupations (existing major group)

33-9000 Other Protective Service Workers (existing minor group)

33-9090 Miscellaneous Protective Service Workers (existing broad occupation)

33-9094 Public Safety Telecommunicators (new detailed occupation)

In APCO’s comments in response to OMB’s Public Notice, we argued that classification within the Office and Administrative Support major group is inappropriate given the stress, training, and life-saving nature of the tasks performed by Public Safety Telecommunicators. Unlike non-emergency dispatchers, Public Safety Telecommunicators receive calls from people whose lives are in danger. Whether answering a phone call to 9-1-1 or a call for assistance from a first responder over the radio, the Public Safety Telecommunicator is responsible for actions that can mean the difference between life and death.

Public Safety Telecommunicators play a critical role in emergency response. The work they perform goes far beyond merely relaying information between the public and first responders. When responding to reports of missing, abducted, and sexually exploited children, the information obtained and actions taken by Public Safety Telecommunicators form the foundation for an effective response. When a hostage taker or suicidal person calls 9-1-1, the first contact is with the Public Safety Telecommunicator whose negotiation skills can prevent the situation from getting worse. During active shooter incidents, Public Safety Telecommunicators coach callers through first aid and give advice to prevent further harm, all while collecting vital information to provide situational awareness for responding officers. And when police officers, firefighters, and EMTs are being shot at, their calls for help go to Public Safety Telecommunicators. They are often communicating with people in great distress, harm, fear, or injury, while employing their experience and training to recognize a critical piece of information. In fact, there have been incidents in which Public Safety Telecommunicators, recognizing the sound of a racked shotgun, have prevented serious harm or death of law enforcement officers who would have otherwise walked into a trap.

This work comes with an extreme emotional and physical impact that is compounded by long hours and the around-the-clock nature of the job. Indeed, research has suggested that Public Safety Telecommunicators are exposed to trauma that may lead to the development of posttraumatic stress disorder. Recognizing the risks associated with exposure to traumatic events, some agencies provide Critical Incident Stress Debriefing (CISD) teams to lessen the psychological impact and accelerate recovery for Public Safety Telecommunicators and first responders, alike.

On June 23, the Congressional NextGen 9-1-1 Caucus Co-Chairs – Senator Amy Klobuchar (D-MN), Senator Richard Burr (R-NC), Representative Anna Eshoo (D-CA), and Representative John Shimkus (R-IL) – sent a bipartisan letter to the Office of Management and Budget (OMB) urging OMB to revise the Standard Occupational Classification (SOC) to accurately represent the complex and life-saving nature of the work performed by 9-1-1 professionals. This was a welcome development that will aid APCO’s ongoing efforts to 1) use the title “Public Safety Telecommunicators” (instead of “dispatchers”) and 2) classify them as a “protective” occupation, in the same category as police officers and firefighters (instead of in the administrative/clerical category).

On July 22, OMB published a 2nd Federal Register Notice requesting comments on a review committee’s recommendations for SOC revision. Unfortunately, this Notice did not include APCO’s recommendations. The reason given on the SOC website for rejecting the Co-Chairs’ and APCO’s recommendations is that

“The work performed is that of a dispatcher, not a first responder. Most dispatchers are precluded from administering actual care, talking someone through procedures, or providing advice. Moving the occupation to the Protective Services major group is not appropriate and separating them from the other dispatchers would be confusing. Also, dispatchers are often located in a separate area from first responders and have a different supervisory chain.”

APCO strongly disagreed with this reasoning and immediately took action to leverage the full strength of its membership and every available resource to ensure Public Safety Telecommunicators receive the recognition they deserve, including:

• Holding a webinar soon after OMB’s interim decision, and later a session at APCO’s annual conference on the reclassification process and how members can get involved;
• Creating an online resource, which includes sample comments and a portal to facilitate submitting formal comments and contacting members of Congress;
• Meeting with the federal office managing the SOC revision to better understand their reasoning, convey the importance of this issue and provide additional information to educate OMB;
• Asking APCO members and their colleagues to submit comments to OMB explaining how they protect the public and first responders and to contact their elected officials to seek support;
• Seeking support from leaders on Capitol Hill;
• Conducting targeted outreach to APCO chapter leaders, agency managers and directors, Registered Public-Safety Leaders (RPLs), APCO Institute graduates, and other national-level organizations to provide information and get them involved; and
• Requesting additional information from OMB on the basis for their interim decision.

The reclassification effort also got a boost from Congresswoman Norma Torres, a member of the NextGen 9-1-1 Caucus and former Public Safety Telecommunicator, who sent a letter to OMB describing the protective work performed by Public Safety Telecommunicators and urging reclassification.

After conducting additional research and incorporating the detailed information about the protective nature of the work performed by Public Safety Telecommunicators provided by the membership, APCO submitted comments in response to OMB’s second solicitation of public comments on the SOC.

APCO filed formal comments on September 20 that provided extensive explanation and examples describing the “protective” nature of the work performed by 9-1-1 professionals, building on information submitted by APCO members. APCO also challenged OMB’s pattern of applying ad hoc and arbitrary criteria to Public Safety Telecommunicators, noting that many of the factors used to justify maintaining the status quo are irrelevant to the SOC’s classification principles, and would in fact disqualify many existing and proposed occupations from the Protective Service category.

Here are a few excerpts from APCO’s latest comments:

“Public Safety Telecommunicators provide lifesaving advice, information gathering and analysis that protects the public and first responders. The work they perform goes beyond merely receiving requests and dispatching resources. It’s life or death, and the current representation in the SOC does a disservice to them, as well as to the statistical purposes for which the SOC is designed.”

“[The federal committee] was wrong when it concluded that ‘Most dispatchers are precluded from administering actual care, ‘talking’ someone through procedures, or providing advice.’”

“[The federal committee’s reasoning] is inconsistent with the SOC classification principles and current makeup of the Protective Service Occupations [category] … and [they] should only be considering the nature of the work performed by Public Safety Telecommunicators and whether their lifesaving work is a protective service.”

“Reclassifying Public Safety Telecommunicators as Protective Service Occupations would correct an inappropriate representation in the SOC, recognize these professionals for the lifesaving work they perform and better align the SOC with related classification systems.”

In December 2016, there were two significant contributions of additional support for reclassifying Public Safety Telecommunicators.

First, Rear Admiral (ret.) David Simpson, Chief of the FCC’s Public Safety and Homeland Security Bureau, submitted a letter of support to the SOC Policy Committee.  Among other things, Admiral Simpson explained that from the FCC’s perspective, the SOC Policy Committee’s initial decision to maintain the status quo “reflect(s) an incomplete and inaccurate understanding of the work performed.”  Citing a recent expert advisory group report, Admiral Simpson pointed out that the “public safety telecommunicator’s position has transformed from a clerical staff handling telephone calls and incidents with manual methods, to technically savvy protective service professionals managing multiple integrated technology systems to track and manage public safety field resources and responses.”

Second, APCO has remained in touch with the federal officials involved throughout the revision process.  During an in-person meeting to discuss the comments submitted in September 2016, OMB requested additional information regarding 1) how the roles of 9-1-1 professionals have evolved; 2) whether “Public Safety Telecommunicator” is representative and commonly-used as a title; and 3) how common it is for Public Safety Telecommunicators to operate in the field.

1. How the Roles of 9-1-1 Professionals Have Evolved
   APCO submitted a brief description of how the work performed by 9-1-1 officials has transformed from a clerical role to the lifesaving and increasingly complex tasks required of Public Safety Telecommunicators. This helps explain the misconception of “dispatchers” as Office and Administrative Support Occupations and why the Protective Service Occupations category is more appropriate.
2. “Public Safety Telecommunicator” is Representative and Commonly-Used as a Title
   APCO compared job title data in 2006 and 2016, as well as survey data based on more than 3,000 responses from public safety communications professionals, to demonstrate that “Public Safety Telecommunicator” is an appropriate term for the SOC. Here are a few observations from our research:
   • Variants of “Dispatcher” (Emergency Dispatcher, Dispatcher/Communications Officer, etc.) are used in 35% of the titles (which is a decrease from 46% in 2006).
   • Variants of “Telecommunicator” (Public Safety Telecommunicator, Public Safety Communications Officer, etc.) account for 57% of the total (up from 53% since 2006).
   • We also asked a relevant question in a brief survey to our members – “Do you agree that the term “Public Safety Telecommunicators” can be used to represent 9-1-1 call takers and police, fire, and emergency medical dispatchers?”
     • 97% of respondents said “Yes.”
3. How Common It Is for Public Safety Telecommunicators to Operate in the Field
   As the SOC Policy Committee’s interim decision indicated, the physical location of the work performed is a consideration for how occupations are classified. Thus, APCO’s survey asked:
   • “Do Public Safety Telecommunicators at your agency ever operate in the field to assist with communications on scene (ex – for pre-planned events, major incidents, SWAT call-outs, etc.)?”
     • 78% said “Yes”
   • Of those who responded “No” to that question, more than half indicated that their agency is “considering policies or a training program to have Public Safety Telecommunicators operate in the field.”

On October 18, 2017, the American Heart Association sent a letter of support to OMB, pointing out how PSTs are a critical link in the cardiac arrest chain of survival.

On November 28, 2017, OMB published a final decision in the Federal Register, changing the detailed occupation name to “Public Safety Telecommunicators” but REJECTING the suggestion to reclassify them as Protective Service Occupations. Read a summary of the explanation provided with rebuttals from APCO.

As part of APCO’s ongoing effort to increase recognition and respect for 9-1-1 professionals, we are offering suggestions for job descriptions that will align with the protective, lifesaving nature of the work. These suggestions may look familiar, as they mirror the recommendations APCO made for revising the federal government’s catalogue of occupations and the published findings of APCO’s Project 43 report on Broadband Implications for the PSAP. We are seeing major changes for public safety communications. To improve recruitment, retention, and recognition for 9-1-1 professionals, job descriptions may require updating to highlight the challenging, life-or-death nature of the work performed, and potentially to eliminate or avoid over-emphasizing any clerical tasks that were more relevant to the early days of 9-1-1. Read the full message.

On April 13, 2022, Federal Communications Commission (FCC) Chairwoman Jessica Rosenworcel sent a formal letter to the director of the Office of Management and Budget (OMB) suggesting an update to the federal classification of 9-1-1 professionals. In the letter Chairwoman Rosenworcel discussed the lifesaving nature of the work performed by public safety telecommunicators and the need to recognize these professionals as an essential part of the public safety system. Chairwoman Rosenworcel urged OMB to update the classification of public safety telecommunicators to the Protective Service category “at the next available opportunity” and offered assistance to collaborate with OMB on the reclassification effort. This letter is helpful because OMB has the ability to correct the classification on its own without passage of the 9-1-1 SAVES Act or other congressional directives to do so.

In March 2019, Congresswoman Norma Torres (D-CA) and Congressman Brian Fitzpatrick (R-PA) introduced the Supporting Accurate Views of Emergency Services Act of 2019 (the 9-1-1 SAVES Act), a bill that would appropriately reclassify Public Safety Telecommunicators with other “Protective” occupations. An identical bill was introduced in the Senate by Senator Richard Burr (R-NC) and Senator Amy Klobuchar (D-MN).

In the 116^th and 117^th Congresses there were several efforts to include the provisions of the 9-1-1 SAVES Act as an amendment to the National Defense Authorization Act (NDAA). However, the process for moving the NDAA forward was complex and, unfortunately, each time the House and Senate finalized the NDAA, it was a slimmed-down version that did not include the reclassification provision.

In the final months of 2023, reclassification language was introduced in the House and Senate. In the House, Reps. Torres and Fitzpatrick reintroduced the 9-1-1 SAVES Act (H.R. 6319). In the Senate, Sens. Klobuchar (D-MN), Blackburn (R-TN), Thune (R-SD), and Heinrich (D-NM), introduced the Enhancing First Response Act (S. 3556), which would fix the federal classification of 9-1-1 professionals, and would also improve the information shared during 9-1-1 outages and examine the enhancements being made for 9-1-1 calls made from multi-line telephone systems.

The different House and Senate bills create alternative strategic paths for achieving reclassification. APCO worked closely with the co-sponsors and will continue to collaborate with them on the strategy for correcting the SOC.

In June, OMB announced the beginning of a multi-year process to revise to Standard Occupational Classification (SOC). As part of this process, OMB is seeking comments from the public on the current SOC classifications. APCO has created a downloadable template for interested members to use to file comments with OMB in support of reclassifying Public Safety Telecommunicators as a Protective Service Occupation.