NTSB Safety Recommendation Letter P-73-012 through P-73-028

Page 1Official PDFsk d not to exceed the penalty provided above or 10 times the amount of additional excavation or demolition costs which such per- son c o u l d have incurred when in compk- ance.[29j Provisions are provided which stop or prevent negligent or unsafe excavation or pro- posed excavation work. The National Association of Regulatory Ut& ity Commissioners’ Gas Committee is also pre- paring a composite statute based on proposed and existing State laws and o n the OPS model statute. deter potential violatots and to encourage co- operation by all parties concerned. Regulatory measures alone will not prevent damage. The OSHA regulations, if complied with by the excavators, might be all that are needed. Statutes and regulations must be aug- mented by ongoing damage-prevention pro- grams of the pipeline operators. These programs must be given priority and must provide the rapid service that the excavator needs to avoid damaging an operator’s facilities. The assistance of the excavator and his machine operator in determining methods o f and cooperation in avoiding damage should be enthusiastically sought. They should be educated as to the dam- age and loss of life which they can cause and should be given as much assistance as necessary to help them avoid hitting a pipeline. On the other hand, both contractors and machine oper- ators should be licensed and have their licenses revoked if they will not cooperate and if they continue to cause accidents. A concerted effort by all parties involved can drastically reduce the number of excavation accidents. V. CONCLZJSIONS Pipeline accidents caused by excavation and construction activities, including blasting, can be prevented. Although new technological advance- ments and new concepts should be developed, the hardware and the knowledge currently avail- able in many parts of the country can be used to r d w e the number of excavationdamage acci- The major effort must come on the local L. . T h e operators of all underground systems must work together with local government offic- ials, contractor associations, individual contrac- tors, State officials, planners, and developers. The first step in achieving cooperation is gener- ally the formulation of a Utility Coordinating Committee in a local area. In many instances, these committees will need guidance and a back- ground of local and State laws and regulations to assist them iii preventing damage during excava- tion activities. Guidance and assistance could come from statewide coordinating committees and even a national organization of Utility Coordinating Committees, which could help distribute infor- ma tion concerning the latest tcchniques and m e t h o d s o f preventing damage. Regulatory measures should require notification of excava- tion work and should be sufficiently flexible to permit the operators of underground systems to establish convenient methods of receiving ification. Penalties should be adequate to 23 VI. RECqMMEN DAT.lONS T h e National Transportation Safety Board recommends rhat: 1. The Office of Pipeline Safery of the De- partment of Transportation: (a) Amend 49 CFR 192 and 49 CFR 195 to require each pipeline operator to establish a program for the prevention of excavation-type damage to its un- derground facilities5 (Recommenda- tion No. P-73-12) (b) Revise its methods of summarizing the reports o f individual gas pipeline leaks and failures to show clearly those ac- cidents resulting from excavation ac- t i v i t i e s , ( R e c o m m e n d a t i o n No. P-73-131#

Page 2(c) Amend CFR 192 and 49 CFR 195 to require that consideration be given during the design of pipelines to pre- vention of damage to them in the fu- ture, especially in locarions where later e x c a v a t i o n might b e e x p e c t e d . (Recommendarion No. P-7.3-14) 2. The American Public Works Association: (a) Encourage its local chapters to estab- lish Utility Coordinating Committees in all urban and suburban communities where effective committees are not currently in operation. (Recommenda- tion No. P-73-15) (b) In regard to Recommendation 2(a), develop guidelines that will assist com- munities to develop systems, proced- ures, and organizational arrangements for coordinating and regulating the ac- tivities of all parties working near un- derground facilities. (Recommenda- tion No. P-7.3-16) (c) Encourage its loci1 chapters to adopt standards which show the desired lo- cations for all facilities installed below g r o u n d . ( R e c o m m e n d a t i o n No. P-73-17) (d) Develop standard colors for identify- ing underground facilities to be used for temporary marking and staking by operators of such facilities, and urge local chapters to support adoption and use of these standard colors. (R.ecom- mendation No. P-7.3-18) ( e ) Coordinate, with support from the g r o u p s which participated in the Safety Board's April 18, 1972 sym- posium, the establishment of a na- tional organization of Utility Coord. i n a t i n g Committees. (R.ecommenda- tion No. P-7.3-19) 3. The National Association of Regulatory Utility Commissioners: (a) Urge its member commissions to en- courage the establishment of local and 24 statewide Utility Coordination Com- m i t t e e s w h e r e n o n e x i s t . (Recommendation No. P-7.3-20) (b) Urge its member commissions to pro- pose and support legislation that will help prevent damage. (Recommenda- tion No. P-73-21) (c) Urge its member commissions to pro- pose and support legislation requiring persons planning t o excavate, and op- erators of excavation equipment to be licensed. ( R e c o m m e n d a t i o n No. P-7.3-22) 4 . The American Society of Mechanical En- gineers Gas Piping Standards Committee: (a) Develop guidelines that can be fol- lowed by gas pipeline operators during design and installation of piping sys- tems, with emphasis o n prevention of f u t u r e excavation damage. (Recom- mendation No. P-7.3-23) (b) Develop guidelines t o assist gas pipe- line operators in establishing excava- t i o n damage prevention programs. (Recommendation No. P-73-24) 5. The American National Standards lnstitute Section Committee for Liquid Petroleum T r a n s p o r t a t i o n Piping Systems (ANSI B31.4) include in its standards the require- ment that consideration be given, during design and installation of liquid piping systems, to avoiding future excavation damage. (Recommendation No. P-73-25) 6. The American Petroleum Institute de- velop guidelines to assist liquid pipeline operators to establish excavation-oriented damage prevention programs. (Recom- mendation No. P-73-26) 7. T h e American General Contractors of America and tb.e International Union of Operating Engineers develop guidelines to be used by contractors and machine op- erators prior to and during construction,#

Page 3.h emphasis on prevenrion of damage to lerground facilities. (Recommendation No. P-73-27) 8. The American Gas Association and the In- d e p e n d e n t Natural Gas Association of America design a standard gas pipeline marker that can be utilized by dl gas pipe- line operators to mark the location of their transmission pipelines. (Recommendation No. P-73-28) BY THE NATIONAL TRANSPORTATION SAFE,TY BOARD / s i JOHN H. REED Chairman I s / FRANCIS H. McADAMS Member /s/ LOUIS M. THAYER Member Is/ WILLIAM R. HALEY Member Isabel A. Burgess, Member, was nor present and did not participate in the adoption of this report. June 7, 1973 25#