12 Aug Working Around Underground Utilities – JSA

Working Around Underground Utilities Job Safety Analysis (JSA)

Job / Task

Planning, locating, exposing, excavating, drilling, trenching, grading, boring, driving stakes or posts, and performing other work near underground electrical, gas, water, sewer, communication, petroleum, and other buried utility systems.

Purpose

This Job Safety Analysis (JSA), also known as a Job Hazard Analysis (JHA), identifies hazards associated with working around underground utilities and establishes controls to prevent electrocution, fire, explosion, flooding, hazardous releases, utility damage, struck-by incidents, and service interruptions.

Personnel Qualifications

Employees performing excavation or other ground-disturbing work shall be trained in applicable utility-location requirements, site procedures, safe excavation practices, and emergency response. Equipment operators shall be trained and authorized for the equipment used.

Employees shall:

• Understand the scope and limits of the planned ground disturbance.
• Review available utility markings, drawings, records, and site information before work begins.
• Know that utility markings indicate an approximate location and do not eliminate the need for careful exposure.
• Use required hand-digging, vacuum excavation, or other approved methods when approaching underground installations.
• Protect exposed utilities from damage and unsupported movement.
• Immediately report damaged markings, unknown utilities, or discrepancies between markings and actual conditions.
• Know emergency procedures for electrical, gas, water, sewer, and other utility contacts.
• Stop work whenever the location, identity, or condition of an underground installation is uncertain.

Required PPE

PPE shall be selected based on the work activity and utility hazards and may include:

• Hard hat.
• Safety glasses with side protection.
• Safety footwear.
• High-visibility apparel.
• Work gloves appropriate to the task.
• Hearing protection where required.
• Electrical protective equipment when specifically required for the task and exposure.
• Chemical-resistant PPE where hazardous liquids or contaminated soil may be encountered.
• Additional task-specific PPE identified by the hazard assessment.

JSA – Job Steps, Hazards, and Controls

Step 1 – Plan the Ground-Disturbing Work

Potential Hazards

• Utility strike.
• Electrocution.
• Fire or explosion.
• Flooding or service interruption.

Required Controls

• Define the limits, depth, and method of excavation or ground disturbance.
• Identify the type of work to be performed, including excavation, trenching, drilling, boring, grading, post driving, or similar activity.
• Review known utility information and site conditions.
• Determine whether permits, utility notifications, owner coordination, or additional approvals are required.
• Communicate the utility-control plan to affected employees and equipment operators.

Step 2 – Notify the Utility-Locating Service / Facility Owner

Potential Hazards

• Unmarked underground installation.
• Incorrect utility information.

Required Controls

• Make required utility-location notifications before ground disturbance begins.
• Allow required response time before excavation.
• Coordinate with private facility owners for utilities not covered by the public locating service.
• Do not begin ground disturbance until required utility responses have been received or applicable procedures permit work to proceed.
• Maintain required notification or ticket information at the work site as applicable.

Step 3 – Review Utility Markings and Records

Potential Hazards

• Misidentified utility.
• Incorrect excavation location.

Required Controls

• Review markings, maps, as-built drawings, owner information, and visible utility features.
• Compare markings with meters, valves, transformers, pedestals, manholes, hydrants, cleanouts, and other surface indicators.
• Identify utilities that may not be shown on available drawings.
• Discuss discrepancies with the responsible utility or site representative.
• Do not assume records or markings provide exact depth or location.

Step 4 – Conduct a Site Walkdown

Potential Hazards

• Unrecognized utility.
• Traffic exposure.
• Trip or fall.

Required Controls

• Walk the proposed work area before excavation.
• Look for utility structures, disturbed soil, pavement cuts, conduit entrances, service lines, and other indications of buried installations.
• Identify overhead lines, traffic, pedestrians, structures, excavations, and equipment hazards that may affect the work.
• Verify the planned excavation limits are clearly identified.
• Establish controlled work zones where needed.

Step 5 – Protect Utility Markings

Potential Hazards

• Loss of utility-location information.
• Accidental excavation in the wrong area.

Required Controls

• Preserve utility markings throughout the work.
• Avoid placing spoil piles, materials, or equipment over markings where practical.
• Refresh or request remarking when markings become faded, disturbed, or no longer visible.
• Do not rely on memory when markings have been destroyed.
• Stop work if required markings cannot be positively identified.

Step 6 – Conduct the Pre-Task Briefing

Potential Hazards

• Miscommunication.
• Worker unaware of utility hazards.

Required Controls

• Review known utility types, approximate locations, expected depths, tolerance zones, and exposure methods.
• Identify the person responsible for directing excavation near utilities.
• Review equipment limitations and spotter requirements.
• Discuss stop-work criteria and emergency procedures.
• Ensure employees understand that unexpected utilities may be encountered.

Step 7 – Establish the Tolerance / Hand-Exposure Zone

Potential Hazards

• Mechanical contact with utility.
• Utility rupture.

Required Controls

• Identify the applicable tolerance zone around marked underground installations.
• Use the excavation method required by law, utility-owner requirements, and company procedures within that zone.
• Do not use aggressive mechanical excavation where safe exposure is required.
• Account for the possible width and depth of the underground installation.
• Expand the controlled area if actual utility location differs from markings.

Step 8 – Pothole / Daylight the Utility

Potential Hazards

• Electrical contact.
• Gas release.
• Damage from hand tools.
• Flying debris.

Required Controls

• Use hand digging, vacuum excavation, or another approved non-destructive method to determine the utility’s exact location.
• Use insulated or nonconductive tools where required by the hazard assessment or utility owner.
• Use caution with pointed tools around known utilities.
• Expose enough of the installation to verify horizontal and vertical location where necessary.
• Keep employees clear of vacuum excavation discharge and pressurized equipment hazards.

Step 9 – Mechanically Excavate Near Utilities

Potential Hazards

• Utility strike.
• Equipment contact.
• Fire, explosion, electrocution, or flooding.

Required Controls

• Use mechanical equipment only when adequate utility clearance has been established.
• Operate slowly and use controlled bucket or cutting movements.
• Use a spotter when the operator cannot clearly see the utility or excavation limits.
• Maintain the required separation between mechanical equipment and exposed utilities.
• Stop mechanical excavation and re-expose by an approved method when utility location becomes uncertain.

Step 10 – Use a Spotter Around Underground Utilities

Potential Hazards

• Miscommunication.
• Spotter struck by equipment.
• Utility contact.

Required Controls

• Designate one spotter when practical and establish clear hand signals or radio communication.
• Position the spotter where both the equipment and excavation can be observed without entering the equipment danger zone.
• Keep the spotter outside swing radii, backing paths, and pinch points.
• Stop equipment immediately if communication with the spotter is lost.
• Resume only after communication and safe positioning are restored.

Step 11 – Work Near Underground Electrical Lines

Potential Hazards

• Electrocution.
• Arc flash or arc blast.
• Fire.

Required Controls

• Treat underground electrical installations as energized unless verified otherwise by the responsible authorized party.
• Do not touch damaged or exposed electrical cables, conduits, or associated equipment.
• Use safe excavation methods and maintain required separation.
• Keep employees away from equipment that has contacted an energized line until the electrical hazard has been controlled.
• Follow site emergency procedures immediately after suspected electrical contact.

Step 12 – Work Near Underground Gas Lines

Potential Hazards

• Fire.
• Explosion.
• Asphyxiation.
• Gas release.

Required Controls

• Use non-destructive exposure methods required by the utility owner or applicable procedures.
• Control ignition sources in areas where gas could be released.
• Do not attempt to repair, bend, move, or manipulate gas lines unless specifically authorized and qualified.
• Watch for hissing, odor, damaged coating, or other indications of leakage.
• Stop work, evacuate the area, and follow emergency procedures if a gas line is damaged or a leak is suspected.

Step 13 – Work Near Water or Sewer Lines

Potential Hazards

• Flooding.
• Cave-in.
• Biological exposure.
• Property damage.

Required Controls

• Expose lines carefully before mechanical work in close proximity.
• Protect pipes from equipment loads and unsupported movement.
• Be prepared to stop work if leakage or unexpected water accumulation occurs.
• Use appropriate hygiene and PPE when sewage or contaminated water exposure is possible.
• Reevaluate excavation stability if a water or sewer line is damaged.

Step 14 – Work Near Communication / Fiber-Optic Lines

Potential Hazards

• Service interruption.
• Sharp fiber injury.
• Unexpected utility configuration.

Required Controls

• Locate and expose communication lines before close mechanical excavation.
• Do not pull, bend, cut, or relocate cables without authorization.
• Treat unidentified cables as active until confirmed otherwise.
• Avoid handling damaged fiber-optic cable fragments with bare hands.
• Report damaged communication facilities immediately.

Step 15 – Support Exposed Utilities

Potential Hazards

• Utility sagging or rupture.
• Crushing.
• Service failure.

Required Controls

• Support underground installations when excavation removes their normal soil support.
• Use supports acceptable to the utility owner or qualified person.
• Do not use exposed utilities as steps, handholds, work platforms, or supports for other materials.
• Protect utilities from equipment contact and falling materials.
• Inspect supports as excavation conditions change.

Step 16 – Protect Utilities During Trench Entry

Potential Hazards

• Contact with utility.
• Cave-in.
• Restricted access.

Required Controls

• Coordinate utility hazards with the excavation competent person.
• Maintain required protective systems without loading or damaging exposed utilities.
• Keep access and egress clear of utility lines where practical.
• Do not alter trench boxes, shoring, or other protective systems to accommodate utilities unless the change is approved.
• Keep employees out of excavations with uncontrolled utility hazards.

Step 17 – Perform Horizontal Boring / Directional Drilling Near Utilities

Potential Hazards

• Cross-bore.
• Utility strike.
• Unexpected drill-head emergence.

Required Controls

• Verify existing utilities along the planned bore path.
• Pothole critical crossings and other locations required by the work plan.
• Track the bore head or drill path as required by the equipment and procedure.
• Maintain required separation from existing utilities.
• Stop drilling if tracking information, utility location, or bore-path control becomes uncertain.

Step 18 – Drive Stakes, Posts, Ground Rods, or Anchors

Potential Hazards

• Penetration of buried utility.
• Electrical contact.
• Gas or water-line damage.

Required Controls

• Treat driving or penetrating the ground as ground-disturbing work.
• Verify utility clearance before driving stakes, posts, rods, anchors, or similar items.
• Use the required locating and exposure process for the intended penetration depth.
• Do not assume shallow penetration is safe without verification.
• Stop if unexpected resistance or utility indications are encountered.

Step 19 – Backfill Around Exposed Utilities

Potential Hazards

• Utility damage.
• Pipe displacement.
• Future service failure.

Required Controls

• Inspect exposed utilities for apparent damage before backfilling.
• Use approved bedding or backfill materials where required.
• Place material carefully to avoid damaging coatings, conduits, pipes, cables, or supports.
• Do not drop large rocks or debris directly onto exposed utilities.
• Compact backfill using methods that do not damage the installation.

Step 20 – Respond to an Unknown Utility

Potential Hazards

• Electrocution.
• Fire or explosion.
• Uncontrolled release.

Required Controls

• Stop work immediately when an unmarked or unidentified utility is discovered.
• Keep employees and equipment clear until the installation is identified.
• Notify the supervisor, utility owner, site representative, or other responsible party.
• Do not move, cut, open, or disturb the installation.
• Resume work only after hazards and required controls are established.

Step 21 – Respond to Utility Contact or Damage

Potential Hazards

• Electrocution.
• Explosion.
• Fire.
• Flooding.
• Hazardous release.

Required Controls

• Stop work immediately and warn others to stay clear.
• Do not touch damaged utilities or equipment in contact with an electrical source.
• For suspected gas releases, eliminate ignition sources when this can be done safely and evacuate to a safe location.
• Notify emergency services, the utility owner, site management, and other required parties according to the emergency plan.
• Do not attempt repairs unless specifically trained, qualified, and authorized.

Step 22 – Respond to Electrical Contact by Mobile Equipment

Potential Hazards

• Electrocution from touch or step potential.
• Fire.

Required Controls

• The operator should remain on the equipment when safe to do so and warn others to stay away.
• Do not allow ground personnel to touch the equipment or attached loads until the electrical source is confirmed de-energized.
• If fire or another immediate hazard requires evacuation, follow trained emergency escape procedures intended to minimize simultaneous contact with the equipment and ground.
• Keep the area isolated until the responsible electrical authority confirms it is safe.
• Have the equipment inspected before returning it to service.

Step 23 – Restore and Close the Work Area

Potential Hazards

• Future utility damage.
• Trip hazard.
• Incomplete documentation.

Required Controls

• Verify exposed utilities are adequately protected before final backfill.
• Remove temporary supports only when approved and no longer required.
• Restore markings, warning devices, pavement, or surface conditions as required.
• Document utility damage, repairs, or deviations from expected locations when required.
• Communicate relevant utility information to affected personnel for future work.

General Safe Work Requirements

• Required utility-locating procedures shall be completed before excavation or other ground-disturbing work begins.
• Utility markings shall be protected and maintained for the duration of the work.
• The exact location of underground installations shall be determined by safe and acceptable means as excavation approaches them.
• Employees shall not assume utility depth, alignment, or configuration based solely on surface markings or drawings.
• Mechanical excavation shall be restricted near utilities until adequate clearance has been established.
• Spotters shall be used when equipment operators cannot clearly observe utility locations, clearances, or other critical hazards.
• Exposed underground installations shall be protected, supported, or removed as necessary to safeguard employees and the utility.
• Unknown or unmarked utilities shall not be disturbed until identified and appropriate controls are established.
• Underground electrical lines shall be treated as energized unless verified otherwise by the responsible authorized party.
• Ignition sources shall be controlled when working near gas utilities or where a flammable release could occur.
• Employees shall remain clear of equipment that contacts an energized electrical utility until the electrical hazard is controlled.
• Utility damage or suspected damage shall be reported immediately.
• Only trained, qualified, and authorized personnel shall repair or alter utility systems.
• Excavation protective systems shall not be compromised to accommodate utilities without appropriate review and approval.
• Work shall stop whenever utility location, markings, exposure, equipment clearance, communication, or emergency controls are inadequate.

Training

Employees performing work around underground utilities shall receive training appropriate to their duties. Training shall address utility-locate requirements, markings and tolerance zones, safe exposure methods, equipment and spotter procedures, underground electrical and gas hazards, exposed-utility protection, excavation safety, directional boring or penetrating-ground hazards where applicable, emergency response, utility-damage reporting, and stop-work authority. Equipment operators and employees performing specialized utility exposure shall receive additional training appropriate to the equipment and methods used.

References

• OSHA 29 CFR 1926.651 – Specific Excavation Requirements.
• OSHA 29 CFR 1926 Subpart P – Excavations.
• OSHA 29 CFR 1926.416 – General Requirements for Electrical Safety.
• Applicable state one-call / utility-location requirements.
• Utility-owner requirements, manufacturer instructions, site procedures, and client requirements.