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Board launches No‑811 pilot and EPR audits; investigations find violations in multiple no‑ticket strikes
Summary
The board described a voluntary pilot to collect and investigate damages caused without an 811 ticket, an electronic positive response (EPR) audit program for operators and several recent enforcement outcomes, including notices of probable violation and referrals to the Contractor State License Board.
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The California Underground Safety Board on Sept. 9 outlined a pilot program to collect and investigate damages caused by excavations performed without an 811 ticket and previewed a planned audit program for electronic positive responses (EPRs) from operators. Jeff McClenahan, the board’s senior policy investigator and lead on the pilot, said the “no‑811” reporting channel gives operators a voluntary way to notify the board about proven damages where no ticket existed, enabling prompt investigation. “The goal of the no 811 pilot program is to provide utility operators a voluntary channel to report no‑ticket underground facility damages to the board for investigation,” McClenahan said. Pilot data and early results: Phase 1 (with Southern California Gas Company) produced 76 notifications. Phase 2 expanded participation and had 285 notifications to date, producing 161 open investigations and 23 cases brought before the board; staff reported more board determinations in 2025 and about $38,000 in fines referred to the Contractor State License Board in 2025. Investigators summarized common explanations reported by excavators in pilot cases: workers said they were hand‑digging, performing shallow work, working in a backyard, or believed another party had already called 811. Participating operators supplied photos and on‑site identifiers to corroborate incidents; investigators then cross‑checked ticket records with call centers. Recent enforcement examples presented by staff include: - A Tracy incident in which FK Design & Construction struck a plastic gas main while trenching to repair a water line; the strike caused an ignition and destroyed on‑site equipment. The board found a violation for excavating without notifying the regional notification center and recommended an $8,000 referral to the Contractor State License Board and mandatory completion of the board’s education course. - A Rialto case where ARM Construction struck a natural gas service line in a backyard while installing utilities for an accessory dwelling unit; the board found violations for failure to notify the regional notification center and for not calling 911 after causing damage, and recommended a $1,000 penalty and education course participation. - Phase 3 Communications: investigators alleged excavation close to a natural gas pipeline and identified an expired ticket; Phase 3 initially failed to cooperate with the investigation. The board later found violations for excavating without notifying the regional notification center and for failing to cooperate, referred a $1,000 penalty and required the company to enroll employees in training; the company then completed audits, created ticket‑tracking procedures and registered staff for training. EPR audits: Amy Morford, Northern California supervising investigator, said the investigations division will roll out scheduled EPR audits by the end of the year to evaluate whether operators fulfill statutory obligations to respond to tickets and field‑mark installations. Initial audits will focus on operators with no EPR responses or response rates below 50% and will expand to assess timeliness and quality of responses. Why it matters: No‑ticket damages were identified in industry data as one of the largest single root causes of underground facility damage. The board aims to reduce unreported no‑ticket damage by prioritizing investigations, scaling the pilot statewide and using audits to encourage operator accountability. How to participate: Operators interested in joining the pilot were invited to email digboard@energysafety.ca.gov.

