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Pipeline Safety Stakeholder Communications

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PIPA Recommended Practice BL14

BL14 "Participate to Improve State Excavation Damage Prevention Programs"

Practice Statement All pipeline safety stakeholders should participate in the work of organizations seeking to make improvements to state excavation damage prevention programs, especially efforts to reduce exemptions from participation in one-call systems.

Audience(s): Local Government, Property Developer and Owner, Transmission Pipeline Operator

Practice Description

A state excavation damage prevention program is comprised of a combination of state law, regulation, and procedure intended to facilitate communication between excavators and owners of underground facilities. Generally, excavators submit notices prior to excavation, which the one-call system passes on to affected facility owners in the vicinity of the proposed excavation. The facility owners/operators can then locate and mark their facilities before excavation begins. By facilitating this communication, one-call systems reduce the risk of excavator injury, damage to underground facilities, and construction down-time. Transmission pipeline operators are required by federal pipeline safety regulations to participate in qualified one-call systems. The Common Ground Alliance (CGA) Best Practices are internationally accepted as effective methods of reducing the risk of excavation damage to all underground facilities.

Some state excavation damage prevention laws include exemptions from one-call system participation that detract from the goals of the system. Typical exemptions fall into three categories:

  1. Facility Owners Some state laws exempt owners of specific types of underground facilities from participation in the one-call system. Excavators must contact these facility owners directly for facility locating and marking before excavating. While this exemption allows certain facility owners to avoid the cost of participation, excavators may not be aware of these exemptions and could begin excavating without having all affected utilities located and marked. This could result in damage to those facilities. Types of facility owners exempted by some state laws include municipalities, state departments of transportation, and small water and sewer companies.
  2. Excavators Some excavators are exempted from calling for underground facilities to be located and marked before they begin digging. If the excavator chooses to exercise this exemption, the likelihood of excavation damage is increased. Damage to any type of underground infrastructure could have negative consequences. Thus, these exemptions create safety risks. Types of excavators exempted by some state laws include homeowners and state departments of transportation.
  3. Types of Excavation Excavators are exempted from calling for a utility locate before conducting specific types of excavation. Any excavation can damage underground facilities, especially if the facilities are shallow or the type of excavation changes during the course of the project. Types of excavations exempted by some state laws include road grading.

Many organizations across the country are actively working to improve state excavation damage prevention programs. The Common Ground Alliance (CGA) works at the national level and has recently formed partnerships with regional organizations. Many of these regional organizations existed well before the CGA as damage prevention councils or utility coordinating councils, but have welcomed the CGA's support to broaden their membership base.

A summary of PHMSA damage prevention initiatives is available on PHMSA's Pipeline Safety Stakeholder Communications website.

References