KEN KIRSCHENBAUM, ESQ ALARM - SECURITY INDUSTRY LEGAL EMAIL NEWSLETTER / THE ALARM EXCHANGE You can read all of our articles on our website. Having trouble getting our emails? Change your spam controls and whitelist ken@kirschenbaumesq.com ******************************* More on signals traveling outside US December 13, 2023 ************************** More on signals traveling outside US ************************** Ken, Further to your 12/1/23 column where Stan Corn of Alarms, Inc., was concerned and wanted verification about alarm signals routed outside of America by a Bulgarian communicator maker and a major panel maker installing these communicators in their ETL fire panels, here is what our research and engineering people verified. NAPCO purchased, from a major distributor, a model MQ03-LTE-M-fire communicator. An IP transmission was forced, which was directly transmitted to an IP address NOC/server located in Bulgaria. As this path can easily be verified using a Wireshark analyzer, there is no doubt that this manufacturer's commercial fire communicator sent life safety signals outside the US borders by design. This is undeniable. (see Kirschenbaum's column dated 11/6/23). In regard to a major fire panel manufacturer installing non-UL listed Bulgarian communicators in their fire panels, we verified that these are programmed to use Amazon Web Services (AWS) as their NOC server. AWS is a network of servers with Data Centers in various locations around the world. You never know where the signal is going. It could be America or outside the US. AWS is a service that retail fast food stores, department stores, and a wide variety of consumer and business credit card companies use. It’s a shared cloud service and if it gets overloaded, and that happens, AWS can slow or stop functioning from time to time. Check out https://downdetector.com/status/aws-amazon-web-services. It is NAPCO's opinion that life safety alarm and fire signals should use dedicated servers in America whose only function is to process Alarm Signals. NAPCO is proud that its UL communicators send their signals to our in-house designed UL NOC/servers in New York and a redundant NOC in Pennsylvania, which sends our signals to the dealers' UL central station. We think it's important for dealers, fire marshals and AHJ's to know where signals are going. As you stated previously in your newsletter dated on 10/25/23: "Some, maybe all, governmental agencies do not permit monitoring by overseas central stations. These agencies include defense industry facilities; that's federal requirements. There are also state agency requirements that prohibit central stations outside of the US. I believe the requirement is so comprehensive that not only can't defense facilities have overseas monitoring but anyone doing business with the defense department cannot have their facilities monitored by overseas central stations … With this in mind I think there can be a problem with communications passing overseas and back to America." We agree with you, Ken. Best regards, Tom Karl, VP, Corporate Sales NAPCO Security Technologies, Inc ************************* Response ************************* Dealers and central stations should be mindful of this issue and opinions expressed. If delayed or failed communication can be traced to overseas communication pathways and allegedly contribute to fire loss [in particular] or other life safety signals there is likely increased exposure. So some of the pertinent questions are: * are signals traveling outside the US * is outside US communication prohibited by customer regulations * are dealers and central stations aware of products or services that utilize communication pathways that leave the US * are there NRTL guidelines on this issue * is there sufficient information to justifiably target a specific product manufacturer or common communication carrier or a central station using out of US based operations or operators or signal pathways. ********************* STANDARD FORM AGREEMENTS: To order up to date Standard Form Alarm / Security / Fire and related Agreements click here: www.alarmcontracts.com *************************** CONCIERGE LAWYER SERVICE PROGRAM FOR THE ALARM INDUSTRY - You can check out the program and sign up here: https://www.kirschenbaumesq.com/page/concierge or contact our Program Coordinator Stacy Spector, Esq at 516 747 6700 x 304. *********************** WEBINARS:https://www.kirschenbaumesq.com/page/alarm-webinars *********************** ALARM ARTICLES: You can always read our Articles on our website at www.kirschenbaumesq.com/page/alarm-articles updated daily ************************* THE ALARM EXCHANGE - the alarm industries leading classified and business exchange - updated daily. https://www.kirschenbaumesq.com/page/alarm-exchange ************************* Wondering how much your alarm company is worth? Click here: https://www.kirschenbaumesq.com/page/what-is-my-alarm-company-worth ****************************** Getting on our email list / Articles archived: Many of you are forwarding these emails to friends or asking that others be added to the list. Sign up for our daily newsletter here: Sign Up. ************************** Ken Kirschenbaum,Esq Kirschenbaum & Kirschenbaum PC Attorneys at Law 200 Garden City Plaza Garden City, NY 11530 516 747 6700 x 301 ken@kirschenbaumesq.com www.KirschenbaumEsq.com
