INTRODUCTION
The private locate industry is like the old Wild West; there are no specific regulations, guidelines, standards, or best practices with regards to having privately-owned buried facilities located and marked prior to excavation. This guideline is for you if you have ever hired a private utility locator (aka private locate contractor or private locate service provider (LSP)) and asked yourself, what exactly is the service they are providing, or who is responsible if we hit a buried facility?
From a technical perspective, the public and private locate processes by which public and private utility infrastructure is physically traced and marked are very similar; in fact, the locate equipment, procedures and operational requirements are virtually the same. However, the process of how a public locate and private locate are conducted are somewhat different.
When any locator does not have the necessary tools to do the job properly (i.e. access, drawings, or support from the utility owner), the RISK of missing or inaccurately locating a buried facility increases. Information management is the primary factor that sets apart both private and public locators, and how they perform their utility locates. A public locator is given drawings and access to facilities by the public utility owner, whereas a private locator must request drawings and access from the person who hired their services. Unfortunately, it is rare that utility records or support is provided from the landowner to the private locator for a variety of reasons. The drawings may not exist, or the person receiving the request does not understand their importance, resulting in little effort to find them. Other factors can include but are not limited to, out-of-date or inaccurate drawings, no access to connection points and utility rooms, and no private landowner operations support.
We have created this guideline for any person or company performing ground disturbing work on private property, landowners, and LSPs, to ensure that everyone knows their role in the private locate process, what is needed from all parties to understand their role and how to mitigate the risks to ensure that all private locates are performed accurately so that risk is kept to a minimum. This guideline will help everyone understand the why, who, when, and how private locates should be performed.
PRIVATELY-OWNED BURIED FACILITY AWARENESS
Prior to excavating, the excavator must be aware that privately-owned buried facilities (aka utility infrastructure) may exist within the work area and should have these facilities located and marked prior to any ground disturbance activity.
Privately-owned buried facilities will not be marked by representatives of the public utility owners beyond the demarcation point of each facility on private property. The excavator should work with a private locate service provider (LSP) and the private landowner to ensure privately-owned buried infrastructure is located and marked prior to excavation.
PRIVATE LOCATES
A Private Locate should be performed when excavating on private property to locate and mark privately-owned buried facilities.
A Private Locate is performed by a Private Locate Service Provider (LSP) to locate and mark buried privately-owned facilities on behalf of the private landowner. These privately-owned buried facilities are those on private property after the public utility owned demarcation point. These private facilities are owned and maintained by the private property landowner. When excavating on private property, the excavator, or private landowner, should hire a private LSP to locate and mark privately owned buried facilities. The locates performed by private LSPs are typically called Private Locates and the Locate Technicians that mark private facilities are typically called Private Locators.
There are two types of Private Utility Locates:
Private Locate with Support
A private locator needs support from the private landowner to provide information with respect to the buried utility infrastructure on their property that they own and maintain. This information includes an inventory of all privately-owned buried facilities that exist on the property as well as their general location that can be found via utility records or site operations personnel.
Private Locate without Support
Private LSPs are often challenged to work “blind” without any support (as previously mentioned) from the private landowner and must sleuth out the privately-owned utility infrastructure network, which increases the chance of missing a buried facility. When support from the landowner is not provided, the Private LSP is challenged to protect underground assets and is contractually bound to a third-party client which places the Private LSP in a difficult position. This type of private locate has many risks that are not always understood by all parties, and when a damage occurs, the Private LSP is perceived to be accountable for restitution of errors and omissions beyond their control.
REQUIREMENTS TO PERFORM AN ACCURATE PRIVATE LOCATE
A Private Locator requires information to perform an accurate locate for privately owned buried facilities. These can be supplied to the private locator by the excavator on behalf of the private landowner, or from the private landowner directly.
A Private LSP requires similar information that an LSP working for a utility owner requires to mark public locates. The private property utility locate information required from the excavator or private landowner includes:
Public Locates for the work area
Private Landowner Utility Records
Access to Privately-Owned Above Ground Utility Infrastructure
Site Operations Assistance from Landowner (if needed)
As previously discussed, when all, or some, of this information is not provided to the private locate technician, the chance of missing a buried private facility increases greatly, thus increasing the risk of facility damage.
PRIVATE LOCATE METHODOLOGY
To ensure an accurate private locate, it is important that a private locator follows a consistent methodology.
A private locate technician should locate and mark a buried facility by working through the following procedural steps when providing an accurate private locate:
Step 1. Review records of a buried facility to understand its path and where the connection points
are to perform an active locate. These records should include, but are not limited to:
a. Public Locates for the work area
b. Architectural, construction, or as-built drawings
c. Survey for the property
Step 2. Interview site operations personnel to further help with identifying potential buried facilities on-site.
Step 3. Visually inspect the work area and all site building mechanical rooms and any other areas suspect of containing above ground utility structures.
Step 4. Locate all buried facilities using the following methods:
a. Actively locate all known buried facilities within the work area using cable and pipe locate
equipment
b. Use passive locating techniques to find any unknowns
c. Perform an inductive sweep of the work area to find any unknowns
d. If needed, use any other non-standard locating techniques that may include ground penetrating radar, electromagnetic survey equipment, and acoustic emission testing equipment.
Step 5. Mark the buried facility using one, or a variety of marking methods (paint, flags, offset markers, etc.).
Step 6. Prepare a detailed private locate report for the private locate.
EXCAVATOR’S ROLE
The excavator plays an important role in the private locate process when hiring a private LSP. When the excavator hires the private LSP, they must act as a liaison between the private LSP and the private landowner.
When an excavator works on private property and hires a Private LSP, they should obtain the following from the private landowner to ensure the private locate technician has everything they need to perform an accurate locate:
Public Locates for the work area
Private Landowner Utility Records
Access to Privately-owned Above Ground Utility Infrastructure
Site Operations Assistance from the Landowner
When all or some of this information is not provided to the Private Locator, they will not have the tools they need to perform an accurate locate and the risk of missing a buried facility increases.
PRIVATE LANDOWNER’S ROLE
The private landowner plays an important role in the private locate process when hiring a private LSP.
When the private landowner directly hires the private LSP, they must provide the following information to the private locate technician before performing a private locate on their property.
Public Locates for the work area
Private Landowner Utility Records
Access to Privately-owned Above Ground Utility Infrastructure
Site Operations Assistance
PRIVATE LOCATE REPORT
A private locate report should be prepared by the private locate technician for their private locate.
A private locate report is a record of the findings prepared by the private locate technician. The report at a minimum should include the following information:
a. Client contact information
b. Site Address / Location
c. Drawing of the work area depicting buildings, above ground utility structures and buried facility marks on the ground
d. A Limitations Section noting any factor that limited their ability to perform an accurate locate
DOCUMENTING UTILITY LOCATE LIMITATIONS
When a Private Locator is presented with an issue that limits their ability to provide an accurate locate, the issue becomes a limitation that needs to be documented on the private locate report for the excavator and private landowner.
Any limitation that a Private Locate Technician encounters while investigating, locating, and marking increases the risk of missing a buried facility. These limitations can be grouped into two types:
Unavoidable Limitations
· non-tonable facilities
· non-locatable facilities due to depth or angled facilities
· fixes or repairs with non-conductive materials
· non-functioning tracer wires
· no tracer wires on non-tonable facilities
· no records exist
Avoidable Limitations
· utility records are not available or provided
· no access to buildings and mechanical rooms
· no direct access to connection points for facilities
· no access to site operations personnel that have knowledge of the property’s utility infrastructure and mechanical systems
MANAGING LIMITATIONS AND SPECIAL INSTRUCTIONS
If a limitation, or special instruction, is noted on the private locate report, it needs to be acted upon prior to excavating to ensure that proper care is taken when excavating near private buried facilities. Any limitation increases the risk of missing a buried facility during the private locate.
When any of these limitations are identified, the excavator should notify either their Supervisor, Project Manager, Client, and/or Private Landowner for direction. Furthermore, the excavator should not proceed with mechanical excavation activities until clear direction is given from the private utility owner or they assume the risk of working with an inaccurate locate.
If you have any comments with regards to this post or a point of view that you would like to share, please message me at grant.piraine@ownyoursafety.com. Have a Safe and Wonderful Day!