Best Practices 30 Day Review

PROPOSED MODIFICATION TO PRACTICE 5-8 

5.8 Positive Response

Practice Statement:

The 811 Center notifies the underground facility owner/operator of the proposed excavation area within the time specified.  The underground facility owner/operator notifies the excavator/contractor of the status of the ticket by providing an electronic positive response through the 811 center.

Practice Description:

Once a facility owners/operator marks the location of existing facilities in the proposed excavation area or determines that excavation or demolition is not in conflict with any of its existing underground facilities, it notifies the excavator of the status of the ticket by appropriate response code through the 811 center’s positive response system, usually “marked” or “clear”.  In addition to positive response, additional communication may be made by any reasonable manner including, but not limited to, face-to-face communications, phone, or other electronic means.

The excavator reviews positive response from the notified owner/operators on the ticket before beginning excavation.  If an excavator has knowledge of the existence of an underground facility and has received a “no conflict,” a prudent excavator notifies the 811 center that a conflict does indeed exist, and the locator will make marking these facilities a priority before excavation begins.  Better communication between the excavator and the facility owner/operator is required as an area of excavation becomes more crowded with new underground facilities.

“Positive response” means an automated information system that allows excavators, locators, operators, and other interested parties to determine the status of a locate request until excavation or demolition is complete.

This action allows the facility owner/operator to communicate the status of the one-call ticket to the excavator through the 811 center as available.

When the excavator makes the request to the 811 center, the excavator is informed which facility owners/operators will be notified.  The excavator reviews all positive responses and compares these to the list of all owner/operators notified on the ticket prior to beginning excavation.  Upon review, the excavator notifies the 811 center of any discrepancy between the positive responses and the field conditions.

References:

• Existing state laws, including California, Maryland, Nevada, and others
• Existing operating procedure for various one call centers (over 40 participating states or 811 centers)
  

PROPOSED NEW PRACTICE – Trouble Locate (Unlocatable) Resolution Period

Trouble Locate (Unlocatable) Resolution Protocol

Practice Statement:

This practice is not intended to circumvent existing statutory language regarding ticket processing but rather provide supplemental tools to reduce damage potential and maintain Excavator productivity.  In response to a valid One Call request, and upon initial arrival at the location, a facility within the proposed excavation area is determined to be unlocatable (aka trouble locate) and based on the Operator’s compliant mark out criteria, the tolerance zone cannot be established with confidence.

In this scenario the Locate Entity:

·       Applies any initial locate protocols available to them that may result in establishing the tolerance zone and placing markings to avoid unnecessary escalation.

·       After exhausting initial trouble locate protocols, and prior to the required marking date, escalates the trouble locate internally for advanced/enhanced resolution measures, i.e., Vacuum Truck, Line Tracer, GPR, In-line 3D Gyro Mapping technology, etc.

·       Attempts to make direct contact with the excavator (cell phone, text, email) and documents the method and message.  If a specific interim positive response code is available or comments can be placed in the 811 center system, share why the locate cannot be completed, along with contact information.

·       Designates the trouble locate area consistent with their procedures and using paint, flags, or other methods that distinguishes the specific trouble area, from the locatable areas.

·       Prioritizes the completion of the Trouble Locate and maintains communication with the Excavator until resolved.  In this communication the Operator should warn of any unique or elevated risk associated with the unlocatable facility (high pressure gas, high voltage electric, high density fiber, etc.).

·       Operator makes the appropriate records/mapping corrections, and when feasible takes action to make the facility locatable going forward (tracer wire, EMS-Marker Balls, etc.).

·       Completes the appropriate positive response in jurisdictions that provide the option.

Practice Description:

The operator has a trouble locate resolution protocol that emphasizes the timely and accurate completion of the trouble locate request with communication between the parties and documentation of actions taken.  Consider Damage Prevention Institute (DPI) metrics that track On-Time Performance and resolution of Trouble Locates.

Benefits:

Enhances communication and documentation between the parties, keeps the Excavator working in non-trouble areas when applicable, improves Operator’s facility records, and reduces damages to at-risk facilities that could otherwise cause a delay.

References:

• Existing practice by Southwest Gas operating in Arizona, California, and Nevada; UGI Utilities, Inc., operating in Pennsylvania and Maryland; NiSource operating in Indiana.

PROPOSED MODIFICATION TO PRACTICE 5-9 

5.9 Facility Owner/Operator Failure to Respond

Practice Statement:

If the facility owner/operator fails to respond to the excavator’s timely request for a locate (e.g., within the time specified by state/provincial requirements) or if the facility owner/operator notifies the excavator that the underground facility cannot be marked within the time frame and a mutually agreeable date for marking cannot be arrived at, then the excavator re-notifies the 811 center, if required by local law.  Once positive response is received from all operators, or if the appropriate waiting period as defined by state/provincial law has lapsed, the excavator may proceed with excavation, provided the excavator exercises reasonable care in all endeavors.

Practice Description:

The facility owner/operator and the excavator partner together to ensure that facilities are marked in an acceptable time frame to allow for underground facility protection.

References:

• Existing state laws, including Ohio, Kansas, South Carolina, Michigan, California, Pennsylvania, and others

5.10 Locate Verification

Practice Statement:

Prior to excavation, excavators verify that they are at the correct location, verify locate markings have been performed by facility owners/operators who have responded as “marked”, and, to the best of their ability, check for unmarked facilities.

Practice Description:

Upon arrival at the excavation site and prior to beginning the excavation, an excavator does the following:

·       Verifies that the dig site matches the 811 request and that the waiting period has ended as defined by state/provincial law

·       Verifies all facility markings are in agreement with the positive responses

·       Checks for any visible signs of underground facilities, such as pedestals, risers, meters, and new trench lines

·       Checks for any facilities that are not members of the 811 center and contact responsible parties  as indicated by state/provincial laws to request their assistance for locates.

Use of a pre-excavation checklist is recommended by insurers and practiced by responsible excavating contractors.

References:

• Existing practice by excavators, including Pauley Construction, Charge EPC, Inc., and W.F. Wilson & Sons, Inc.
• CGA Best Practice 4-21