Hi, I think you will find that 911 or here in Australia 000 calls should not require a SIM, I know that my phone if out of service area for my carrier, will if 000 go scanning for a network to connect to.
The phone I use at work for pics has no SIM so I might try it.
NOKIA the only mobile phone, unfortunately its now a Microsoft phone.....sob sob..sob.... =( =( =(
Tom...... 
PS, the fact that its no a full blown handheld phone might be the difference.