Board weighs safety standards for operator response to unmarked lines

The California Underground Safety Board discussed July 15 how best to address safety problems created when excavators encounter unmarked subsurface lines and clarified staff’s recommendation to focus standards on operators’ communication and response obligations. Why it matters: Board staff said statute empowers the board to draft safety standards but leaves gaps in how excavators and operators should communicate when an unmarked line is found. Staff said the Common Ground Alliance (CGA) best practices advise regional notification centers (RNCs) to have documented policies (for example, resending tickets) but provide little guidance on how operators should respond when notified of an unmarked line. Staff recommendation and rationale: "Staff recommends that the board discuss the issues presented by this lack of safety standard guidance for operator responses and direct staff to focus the content of the board's unmarked line safety standards on appropriate communication practices of operators who are notified of an unmarked line," the staff presenter said. Staff noted that statute requires excavators to report an operator’s failure to identify their subsurface installations to the RNCs, but that the statute is silent about how operators should act after receiving such a notice. Public comment highlights: Industry commenters said unmarked-line incidents are common and complicated by overlapping utilities and legacy or abandoned lines. James Wingate of USA North 811 described instances where excavators exposed a feature that other parties did not identify in the one-call ticket, citing a county traffic-signal shop that is not an RNC member and therefore did not appear in EPR (electronic positive response) results. USA North 811 and others noted examples and said some states use coordinated multi-operator processes to determine ownership and reduce misidentification in the field. Board discussion: Board members and industry speakers agreed the issue affects excavators, RNCs, and operators and raised questions about definitions of “live,” “abandoned,” and “spare” lines. Member questions focused on whether the board should open an enforcement process (a notice of possible determination, NOPD) when unmarked lines cause delays or safety issues; staff said they are reviewing investigative and enforcement options but that logistics — identifying ownership and verifying field evidence — can be complex. Next steps: The board directed staff to continue developing unmarked-line safety standards focused on operator communication and to seek stakeholder input through workshops and public comment processes. Staff will explore enforcement pathways and repository or data-sharing mechanisms as the standards are refined.