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Underground Utility Safety and Damage Prevention

BY ALLEN GRAY, DIRECTOR, UTILITY INFRASTRUCTURE DIVISION, AGC OF AMERICA

Four years ago, I was invited to join the Gold Shovel Association (GSA) Board of Directors to help bring a construction industry perspective to the organization. I accepted the invitation in hopes of helping make the organization more palatable to the construction industry as well as increase public and jobsite safety. Recently I was asked to serve another term but declined. Here is why.

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The GSA is a nonprofit organization founded by facility owner/operators under the leadership of Pacific Gas & Electric (PG&E). The goal of GSA is to require excavators who contract with endorsing facility owner/operators to secure its Gold Shovel Standard (GSS) certi-fication of their underground utility safety and damage prevention program (811 program). In theory, this will help certify that profes-sional excavators have an effective program in place. Although this is a commendable objective, there were and are aspects of the program viewed with a high degree of skepticism by the construction industry.

For instance, the organization was founded with little representative input from the construction industry. Since the organization’s primary pur-pose is to review and judge an excavator’s 811 program, the absence of legitimate construction industry representation in its development led to much consternation when the program launched. The rocky start was compounded by the GSA’s early stated purpose to address issues associated with a September 2010 PG&E pipeline explosion in San Bruno, California, which killed eight people, leveled 35 houses and damaged many more. GSA repeatedly promoted this misinformation even though the San Bruno explosion had nothing to do with underground utility safety and damage pre-vention, 811 or excavation activities. It was determined pipeline installation and maintenance was the root cause of the explosion.

The certification also requires the excavator to upload all information pertaining to excavation activities, including damages to existing facilities, near misses and incidents into a central database that then applies a rating to the excavator based on metrics developed by GSA. According to many GSS-certified excavators the rating is not reasonably normalized and has yet to prove its worth.

One of the most questionable aspects of the program is it was not established to attract excavators; it was designed to coerce them into certifica-tion as a prerequisite to contracting with owner/operators, including public owners. Instead of allowing excavators to pursue certification on their own for its face value, they are forced to secure it. Any professional excavator worth their salt have their own robust 811 programs in place based on industry best practices, such as the Common Ground Alliance Best Practices and programs developed by industry associations, such as AGC’s “Ele-ments of an Effective Underground Utility Excavation Safety and Damage Preventions Program” (https://bit.ly/UtilityDamagePreventionProgram).

Finally, the GSA’s overwhelming focus is on the excavator and their responsibility in the 811 process. It is true excavators play an important role in the process; however, of equal, if not more importance are the responsibilities of facility owner/operators and professional facility loca-tors. Over the past year there have been widely reported breakdowns in the 811 process due to facility owner/operators’ failure to respond to tens of thousands of locate requests required by law. As examples, the failures include 78,000 late or no-show responses in Minnesota, 30,000 in Arizona, and 20,000 in Michigan. A major facility owner/operator agreed to pay $65 million to settle claims that they falsified records and misrepresented response time to excavators’ requests to locate and mark gas lines.

When asked to serve another term and after careful consideration, I decided that my time and resources are better spent participating in ef-forts that embrace a more holistic approach to underground utility safety and damage prevention.