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Key Points:
When carriers began retiring copper infrastructure, many organizations assumed the solution was straightforward: swap the POTS line for any available alternative and keep the device running. The compliance picture is more complicated than that.
The devices that depend most on POTS lines, including fire alarm panels, elevator emergency phones, area-of-refuge phones, blue-light phones, and building entry systems, are governed by safety codes that specify not just what the device must do but also how it must communicate.
Replacing the line with a non-compliant alternative does not satisfy those codes. It just creates a different kind of compliance problem.
This is the most demanding compliance requirement in POTS replacement. NFPA 72, the National Fire Alarm and Signaling Code, requires that fire alarm communication paths use a Managed Facilities-based Voice Network. In this managed private network, traffic never traverses the public internet.
This requirement disqualifies standard VoIP solutions, which route traffic over the public internet for at least part of their path.
Beyond the MFVN requirement, the replacement solution must also:
Commonly referenced credentials: The California State Fire Marshal Building Materials Listing and New York City Fire Department approval are among the most widely recognized credentials AHJs reference when evaluating a POTS replacement for fire alarm use. A solution that holds both may have a clearer path to local approval.
ASME A17.1, the Safety Code for Elevators and Escalators, requires a two-way means of communication in every elevator cab.
The communication system must:
A POTS replacement installed at the demarc via a standard RJ-11 jack that does not change the phone hardware, phone number, or panel configuration avoids triggering a full reinspection in most jurisdictions.
The elevator technician who tests and documents the restored communication path can confirm compliance with the AHJ without requiring a panel replacement.
The International Building Code requires two-way communication at areas of refuge, which are locations where people who cannot use stairs wait for evacuation assistance during a fire.
The system must provide both audible and visible signals and must remain operational during a fire event. This means:
The Clery Act requires colleges and universities that receive federal financial aid to maintain emergency notification and response systems, but it does not specify technology requirements.
The compliance documentation, including written emergency response procedures, testing logs, and incident records, is what regulators review.
The ADA governs the physical accessibility of the phones themselves, including hands-free operation, push buttons mounted at an accessible height, and visual and audio confirmation that the call has connected.
A disconnected blue-light phone that appears intact creates both a safety gap and an ADA compliance gap if students with disabilities rely on it.
Local and state codes vary on where emergency phones must be placed and how the communication path must be managed. The Authority Having Jurisdiction for the campus, often the local fire marshal or building inspector, has final authority on what meets code in that jurisdiction.
Building entry and gate access systems are governed primarily by accessibility requirements and building codes rather than a single national safety standard.
The key considerations are:
The AHJ has final say in every jurisdiction. A solution that is certified at the national level still requires local approval.
The organizations with the smoothest transitions are those that bring AHJ documentation to the conversation early, before installation rather than after.
A POTS replacement that installs at the demarc without altering existing panels or monitoring station receivers and carries the relevant national certifications gives the AHJ the clearest path to approval.
Requesting a pre-installation meeting with the AHJ or providing written documentation of the solution’s certifications before work begins is the single most effective step an organization can take to help ensure the transition does not stall at the inspection stage.