Contractors advised to change dig‑ticket habits after SB 778 tweaks to 4216

Logan Downer, cofounder and general manager of Excavate 11, told the California Underground Safety Board on Sept. 8 in Sacramento that recent statutory changes (SB 778) alter how operators must respond to dig tickets and that contractors should adjust ticketing practices to reduce risk and liability.

Why it matters: the statutory language governing how operators must fulfill obligations prior to a ticket's legal start date has changed; contractors, locators and call centers must interpret responses consistently to avoid unsafe excavations and post‑incident disputes.

Downer described several changes to what the meeting referred to as "42 16" provisions and gave field advice. He said the law now requires that, prior to the legal start date and time on a ticket, an operator must do one of the following for the excavator: locate and mark the subsurface installations, provide location information (for example a GPS as‑built), or state there is no conflict. "Now that means they can do three things prior to the legal start date and time," Downer said, adding that elimination of certain legacy response codes should reduce gamesmanship in responses.

Downer also highlighted that under the updated statute an excavator may begin work prior to the ticket's legal start time if all operators on the ticket "have performed their obligations." He further described a new requirement that operators explicitly notify excavators in their responses if vacuum excavation equipment is not permitted near the operator's facilities, and a 1‑day response requirement for operator replies to excavator requests for information (both described in the meeting as changes to the 4216.4 and related subsections).

Practical guidance from Downer included: when creating tickets, leave changeable fields (method, depth, duration) as "unknown" where appropriate so the ticket can accommodate site changes; when possible select mechanical or multiple methods and indicate willingness to use vacuum excavation so operators must state objections in their responses; and always submit requests for additional information through the call center to ensure a time‑stamped ticketed request. "So to make sure that you accurately start the clock… go through the call center that puts it on the ticket that you've made a request for information," Downer advised.

Downer emphasized locating standards: a field mark does not require depth but should follow Common Ground Alliance (CGA) guidance and, where multiple subsurface installations of the same type are known to exist, operators must mark the number of subsurface installations. He urged excavators to report markings that do not indicate the number of conduits to the call center and to pothole to the required depth for due diligence.

He described the practical costs of strikes and management best practices: "Every single day that we're working, we have a moral and ethical responsibility to ensure that safety is our number one priority," Downer said. He also cited a national estimate for 2023: $62,000,000,000 in costs from utility strikes, given as context for why ticket accuracy and field verification matter.

Downer closed with immediate operational steps: use the call center for requests for information, verify operator responses for "clear to dig" codes and confirm whether private utilities might be present, and take photos and notify operators immediately in the event of a strike. He also described the legal reporting windows under existing regulations: report most damages to the call center within 48 hours, and for natural gas, high‑priority utilities, injuries or fatalities, within two hours as required by the regulations presented in the meeting.

No board vote or regulatory change was adopted at the meeting; the session was instructional and intended to help contractors and field crews comply with statutory obligations and best practices.