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San Juan Basin Operators Safety Council
Ground Disturbance / Excavation Procedure
1.0 Minimum Regulatory Requirements
Every company working for the San Juan Basin Operators Safety Council (SJBOSC) companies
are required to follow all requirements in:
29 CFR 1926 subpart P
New Mexico One Call Requirements
Colorado One Call Requirements
Department of Transportation (DOT) regulated pipelines must follow all DOT requirements
2.0 Definitions:
Authorized Company Representative - Individual who can sign Ground Disturbance Permit to allow
Ground Disturbance activities to proceed. This may be an employee of the company, an individual
representing company interests or a contractor employee.
Contact: “A puncture or crack in the facility, scratch, gouge, flattening or dent of the surface, or,
damage to the protective covering”
Competent person: Individuals (employee or contract) who are capable, through experience and/or
training, to identify existing and predictable hazards in the surroundings or working conditions which are
hazardous or dangerous to personnel and who has authorization to take prompt corrective measures to
eliminate such hazards. The primary responsibility for ensuring a safe excavation and/or ground
disturbance as defined by this procedure is assigned to the “Competent person/authorized company
representative”. Competent person/authorized company representative shall demonstrate competency by
means of a written evaluation.
De-energized Facility: Line (gas, water, electrical or other) that has been confirmed de-energized and
locked out / tagged out.
Depressurization: Reducing the pressure on a line or piping system to 0 psig or as close to that pressure
as is reasonable and practical.
Dig Zone: Area of ground to be disturbed
Energized Facility: Line (gas, water, electrical or other) that contains energy such as pressure, electrical
energy or fluids under pressure.
Entry: Introduction of personnel into an excavation or trench to perform any type of work
Excavation: Any man-made cut, cavity, trench or depression in the earth’s surface, formed/caused by
earth removal.
Encroachment: Crossing or paralleling within 10 feet of an existing line
Ground Disturbance: Any excavation, construction or other activity that results in the pentration of the
ground.
Non-Entry: An excavation or trench in which no personnel are to enter for any reason.
Potholing: Hand digging or using a vacuum excavator to make a hole that confirms the exact location,
depth, orientation and line size of a line or other underground facility
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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Protective System: Is a method of protecting employees from cave-ins of material that could fall or roll
from an excavation face or from the collapse of adjacent structures. Protective systems include support
systems, shield systems, and other systems that provide necessary protection.
Qualified Equipment Operator: A person who through experience and/or training and with the
endorsement of their employer is competent to operate equipment used in ground disturbance and/or
excavation activities.
Qualified Line Locator: A person who through experience and/or training and with the endorsement of
their employer is competent to operate line finding equipment used to locate buried facilities prior to
ground disturbance and/or excavation activities.
Restricted Area: A 10’ area in all directions surrounding the dig zone, to be swept with line finding
equipment in which the dedicated ground spotter is required for each excavation/trenching machine...
Risk Assessment: Process of identifying potential hazards and implementing appropriate controls,
(JSA/JHA)
Search Zone: A 25’ area in all directions surrounding the dig zone, to be swept with line finding
equipment
Trench Excavation: A narrow excavation made below the surface of the ground where the depth is
generally greater than the width. However, the width of a trench as measured at the bottom is not greater
than 15 feet.
NOTE: Excavations more than 20 feet in depth must be designed by a registered professional engineer and
are not covered in this policy.
Underground Facility: Any manmade structure located below the surface of the ground.
Vacuum Excavation: An excavating unit that digs by combination of alternating water/air or air/air
pulsations
3.0 Common Requirements
All Ground Disturbance/Excavation activities will require the use of the SJBOSC Ground
Disturbance Permit (Attachment 1)
Equipment operators shall be familiar with the equipment they are using and approved by their
company and the competent person/authorized company representative overseeing ground
disturbance/excavation activities.
No mechanical digging is allowed within 2 feet of any energized facility. See BP Requirement
Construction (dig) zones and search areas will be clearly marked per PRC requirements
Owners of underground facilities shall be notified when their facilities are exposed
Any excavation requiring entry by any personnel shall be supervised by a competent person and
the Excavation Safety Daily Field Report (Attachment 2) shall be completed by the competent
person.
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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4.0 Process
Ground Disturbance/Excavation Permit
A Ground Disturbance Permit (Attachment 1) is required for:



Any mechanical excavation that results in the penetration of the ground;
Any manual ground penetration (e.g., digging with shovels, hammering of stakes, greater
than 24 inches). See BP Exception
Any Hand augering greater than 36”. Hand Augering is permissible for environmental
sampling only. See BP Exception
Exceptions:


Using fill dirt as an alternative to grading low spots or areas where erosion has occurred,
or using stockpiled material does not constitute a Ground Disturbance activity.
For road grading, a One Call is required but permit is not required. See BP exception
San Juan Basin Operators Safety Council Ground Disturbance Permit
Guidance Document
Permit Item1 – One Call Notification
A Competent person/authorized company representative must ensure that the appropriate regional One
Call Notification Center has been notified of all planned excavation activities and a request for line
locates has been registered. The Competent person/authorized company representative will affirm that
responses have been received from all facility owners and that all lines have been located and marked
prior to any excavation activity. When in doubt, the competent person/authorized company
representative will investigate the possibility of underground lines and contact appropriate parties as
needed for verification.
Permit Item 2 – Line Location & Plot Plan
Available records shall be referenced and contacts made to determine the existence and location of
underground facilities/pipelines and utilities in the vicinity of the work area.
It is the Competent person/authorized company representative’s responsibility to confirm that all
available sources of information have been obtained and cross-referenced to ensure, as far as is
reasonable and practical, the existence of all facilities/pipelines and underground utilities is known and
understood. Sources of information, including but not limited to, the following must be referenced
when applicable to the job:
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
Page 1 of 8
One Call, Consult Area Operations Personnel, Visible Company Markers & Visible Indicators of
previous ground disturbance activities, Discussion with Landowner
A plot plan, pipeline or facilities map or lease drawing indicating the location of all underground
facilities and utilities, shall be available for reference at the work site. This drawing may be hand
drawn but must reflect all available information accurately, reverse of the permit should be used for
this plot plan.
Permit Item 3 – All Pipeline Regulations and Guidance are followed
DOT regulations and applicable company regulations are available and reviewed prior to any Ground
Disturbance Activities.
Permit Item 4 – Pre-Job Safety Meetings
A pre-job safety meeting including Job Safety Analysis, Ground Disturbance Permit, and Emergency
Response Plan review will be held. Appropriate documentation of such meeting will be kept with the
permit.
The following topics (as a minimum) must be discussed and the meeting minutes (with signed
attendance list) have been recorded with the permit
Review of potential hazards, safe work procedure, permitting requirements, etc.
Mechanical excavation equipment must not be used to dig within 2’ (or greater if specified in the
crossing agreement) of an underground facility. A equipment spotter must be in place for all
excavation within proximity of any underground utility and the 2’ no dig zone must be adequately
marked.
When excavating, proper cutback and shoring must be done in accordance with local, state and
federal regulations and applicable company policies.
A site-specific Emergency Response Plan must be in place and reviewed at the pre-job meeting.
At a minimum, the Emergency Response Plan must include: facility contact names and phone
numbers, muster area, phone numbers for emergency services, and directions to the work site.
Specific requirements for system isolation procedure and isolation valve locations exist for BP
Ground Disturbance activities.
Permit Item 5 – Facility Marking
All known pipelines and utilities, as noted on the plot plan, pipeline map, or drawing, that pass within
the search zone/restricted area of an underground facility have been located, identified and marked to
indicate location and alignment.
The following PRC color code is to be used:
Nonpotable Water – Purple
Gas & Oil – Yellow
Construction/Dig Zone – White
Edge of Search/Research Zone – Pink
Drainage/Sewers - Green
Potable Water – Blue
Electrical – Red
Communication - Orange
Plot plans, facilities/pipeline map, and drawing must be cross-referenced with the placement of
markers prior to mechanical excavation to ensure there are no apparent inconsistencies. If there are
inconsistencies between the plot plan, facilities/pipeline maps, or drawing and placement of stakes,
another line locate must be performed to verify correct line location and alignment.
Permit Item 6 – Verifying & Exposing Underground Facilities
All underground facilities within 10 ft of the new facility being installed have been safely identified to
verify location, orientation, depth, size and alignment. Based on company policy, this requirement may
require hand digging or vacuum excavation.
Permit Item 7 – Additional Permits
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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Additional Safe Work Permits (e.g., Hot Work, Confined Space Entry, Daily Work Permit, etc.) as per
company policies may be required. If the excavation is complex or involves multiple underground
facilities, job specific procedures must be developed
Permit Item 8 – Overhead Power Lines
Overhead power lines that may pose a hazard during movement of equipment must also be clearly
indicated and clearances must be maintained. Barricades shall be placed to prevent equipment from
inadvertently crossing under a line. A spotter is required to assist equipment operators in maintaining
required safe distances while equipment is in operation.
Permit Item 9 - Environmental Evaluation
Ground Disturbance activities in certain areas may require specific environmental permits or plans.
Ground Disturbance activity projects such as remediation, location restoration and site development
will normally need Ground Disturbance Permits. Items such as wetland disturbance permits, dredging
or filling permits, storm water discharge permits, and critical or sensitive habitat determination and
pollution prevention plans may be required. Archaeological sites may also be present and each
location should be evaluated and permits obtained as applicable.
Permit Item 10 – Notifications to Company Personnel
Notifications to appropriate involved and/or responsible internal personnel (e.g., Land Department,
Managers, Supervisors, Team Leaders, Field Technicians, Mechanics, Drilling/Completion/Workover
personnel etc.) must be made prior to issuance of a permit per company requirements
Permit Item 11 - All excavations shall be made in accordance with the rules, regulations,
requirements, and guidelines set forth in 29 CFR 1926 sub part P. The use of the Construction
Checklist for Trenching is required for all BP Ground Disturbance activities.
Permit Item 12 – Daily Trench Inspections
Daily inspections of excavations greater than 4 feet in depth, adjacent areas, and protective systems
shall be made by a competent person for evidence of a situation that will result in possible cave-ins or
other hazardous conditions. Inspections shall be documented and are required when personnel are
entering trenches.
Permit Item 12 – Non-Traceable Underground Facilities
New non-traceable (nonmetallic) underground installations shall always be installed with permanent
line locating capabilities.
Permit Item 13 – Review of Ground Disturbance Permit
The Competent person/authorized company representative shall confirm that, all involved personnel
on-site review/sign the JSA and permit.
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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Ground Disturbance at a Glance
(Energized Facilities)
Company Specific
BP Every underground facility within 10 feet of
mechanical dig zone must be potholed to
verify alignment, depth, and size
DIG ZONE – area
of mechanical
excavation –
marked with white
flags/paint prior to
excavation
Restricted Area = DIG ZONE + 10 FEET
SEARCH ZONE = DIG ZONE + 25 FEET
Note: No mechanical digging within 2 feet of an energized line.
Ground Disturbance at a Glance
(De-Energized Facilities)
Company Specific
BP - Every underground facility within 10
feet of mechanical dig zone must be
potholed to verify alignment, depth, and
size
Every underground facility in the search
zone must be identified (flagged) to verify
alignment and location
DIG ZONE – area
of mechanical
excavation –
marked with white
flags/paint prior to
excavation
Conoco Phillips - Every underground
facility within 10 feet of mechanical dig
zone must be identified / flagged
Restricted Area = DIG ZONE + 10 FEET
SEARCH ZONE = DIG ZONE + 25 FEET
5.0 Training
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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All Competent persons as defined by OSHA will be required to attend the 8 hour OSHA
training for excavation competent person.
All personnel who authorize Ground Disturbance activities to proceed by signing the
permit shall attend San Juan Basin Operators Safety Council training.
All personnel allowing Ground Disturbance activities to proceed for BP shall attend a
BP sponsored class on Ground Disturbance.
Personnel locating lines shall be trained in the type of equipment they are using and
approved by their company.
All equipment operators involved in Ground Disturbance activities for BP shall attend a
BP sponsored class on Ground Disturbance.
All equipment operators shall be approved by their employers for Ground Disturbance
activities.
6.0 Company Specific Policies
BP:
Additional requirement for Ground Disturbance Activities:

Any mechanical scraping activity (e.g., road grading, bull dozing) that results in the
penetration of the ground.
Any mechanical digging within five (5) feet of an energized facility is prohibited unless a
variance is approved prior to digging.
Competent person/authorized company representative must be on site for all facility
crossing activities and digging around energized facilities.
When digging within 10 feet of an energized line, isolation valves must be function
tested. When digging within 25 feet of an energized line, isolation valves must be
identified on the JHA/JSA or permit.
BP Additional Guidance Documents:
SJA Ground Disturbance Supplemental Practice
SJA Ground Disturbance Variance Process
SJA Driving T Posts, Stakes and Markers
SJA Probing Procedure
Ground Disturbance Permit
Mechanical Scraping and Associated Activities
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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Conoco Phillips:
Equipment operators must have at least one year experience prior to digging around CP
lines.
Spotters must be present for all ground disturbance activities.
7.0 Forms
Attachment 1 – SJBOSC Ground Disturbance Permit
Attachment 2 – Daily Trench Report
Issue Date: 2 Feb 2006
Ground Disturbance/Excavation
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