April 2015, Vol. 70, No.4


DCA Creates Position Paper On Cross Bore Mitigation

EDITOR’S NOTE: The Distribution Contractors Association has taken the initiative to address cross bore issues as they relate to the underground construction community. The DCA Government Relations Committee, co-chaired by Greg Dahl of ARB and Dave Wizniewski of Vermeer, led the effort to create a position paper on this safety issue of critical importance not only to the gas distribution industry, but all aspects of underground work.

“The Distribution Contractors Association is ramping up a multi-tiered strategy to further the discussion of crossbores and offer effective alternatives, best practices and protocols that will lead to their elimination,” Dahl explained. “They are joined in these efforts with other organizations who realize with the increase in underground utility construction, a comprehensive solution to this issue must be found. This solution must include all the involved stakeholders: facility operators, contractors, state and federal entities, and will take significant public awareness, targeted advocacy and dedication at all levels to effect change. To this end, the DCA has formally adopted its own position paper on the issue of cross bores.

“This is the basis for our efforts to move the discussion forward, to identify roles and responsibilities of the involved parties, to quantify the extent of the problem and to be consistent and clear with our message,” Dahl continued. “It is important to note that we are proposing a solution that involves the shared responsibility of all the stakeholders, and not an effort to mitigate or lessen the responsibility of contractors to locate and protect existing substructures during construction.”

He pointed out that “the cross bore issue revolves principally around sewer laterals to homes and businesses. These laterals are generally composed of clay or other non-metallic pipe. Because this material is non-metallic, it is not detectable by ferromagnetic locators used by most utilities or their agents to locate their facilities.”

“A cross bore is defined by the Cross Bore Safety Association as ‘an intersection of an existing underground utility or underground structure by a second utility resulting in direct contact between the transactions of the utilities that compromises the integrity of either utility or underground structure,’ ” Dahl said.

“The DCA believes that ultimately this is a public safety issue and should be treated as such. This may require a fresh approach to the problem. It may require an understanding of historical relationships between property owners and municipalities, and it may demand that a new paradigm be established to ultimately solve the problem,” Dahl emphasized.

The DCA’s position paper is as follows:

Construction activity continues to increase across the country, underscoring the need for steadfast dedication to prevent damages to underground facilities. Crossbores, or intersections of existing underground utilities by a second utility during installation, are enduring problems carrying potentially disastrous consequences. When analyzing the underlying causes of crossbores, as well as alternative ways to address and reduce them, a lack of consistency and clarity is evident among the key stakeholders.

Close working relationships between contractors and their customers in the gas distribution industry can go a long way to reduce crossbores. However, further action is needed by gas utilities, local and state governmental agencies, as well as the federal government to ultimately turn the reduction of crossbores in to total prevention. The DCA believes the following practices and actions will collectively help raise awareness and prevent cross bore scenarios and facility damages across the country.


Contractors utilize a wide range of methods and procedures to recognize and prevent crossbores. These measures may be required by law, job permits and regulations or by mandate of internal/external company policy. While crossbores of sewer laterals are of primary concern, this can also occur on sewer mains. Due to the difficulty of locating non-metallic sewer systems, some contractors do not currently employ these practices – but may find them useful in the future. Others have been utilizing many of these methods for years depending on project-specific criteria. Accordingly, we believe all contractors should consider the following actions to prevent underground facility damages and cross bore situations:

• Call 811 prior to excavation and adhere to all related “call before you dig” requirements;
• Consider Common Ground Alliance (CGA) best practices and related resources when practical;
• To the extent possible, ensure that underground facilities owners who are not members of the one-call system are notified of planned excavation;
• Utilize all job site drawings to establish locations of underground facilities, including information related to depth, position, shape and type of facility;
• Investigate thoroughly, including: on site interviews, evaluation of plat maps, excavation permits, one-call tickets, photographs of related equipment, excavations, facility marks;
• “Pothole” to locate underground facilities when appropriate or required;
• Use subsurface utility verification when practical (camera inspection, ground penetrating radar, acoustic, etc.);
• Maintain supporting documentation (“as-builts,” plat sheets, GIS information, etc.);
• Stop excavation when unsure of existing underground facilities and consult with facility operator(s); and
• Communicate and report underground facility hits according to state law.

Gas utility

There are several procedures and types of equipment used to identify buried utility systems that could be applicable to locating sewer laterals. Because these systems are generally composed of non-metallic material, they tend to be difficult to locate using traditional methods. Technologies such as surface ground penetrating radar (GPR), acoustic/seismic measures, traceable wire, electronic markers or closed-circuit television (CCTV) camera inspections are often necessary to complete the job. While the responsibility to locate and mark underground facilities typically lies with the facility operator, contractors who perform work for the utility companies may be in a better position to locate sewer laterals. Discussions during the bidding process among all parties involved with cross bore mitigation, as well as cost recovery language in gas pipeline agreements, provides the opportunity for contractors to ensure all responsibilities are met in an equitable fashion.

State, local governments

Unmarked sewer laterals remain the single largest cause of crossbores. While state law generally requires underground facility operators to locate and mark their infrastructure prior to excavation, the responsibility for marking and locating sewer laterals continues to be a contentious issue. Municipalities, who generally own and operate the water and sewer systems, are often exempt from one-call membership requirements. This exemption effectively relieves them of their responsibility to locate their sewer systems. To make matters worse, because these laterals generally exist on private property, municipalities often place the responsibility of locating and marking sewer laterals in the hands of unknowing property owners.

It is unrealistic to expect landowners to be aware of, understand, or fulfill the responsibilities associated with locating sewer laterals on their property. Municipalities, who derive revenue from the sewer systems, are best equipped to locate and mark them. This is consistent with best practices developed by the Common Ground Alliance (CGA), who maintains that the “service line is marked in response to a locate request to a governmental entity that provides a product or service to an end-use customer via the service line.”

Federal government

The Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011 included language restricting federal dollars from being allocated to state damage prevention programs. These same programs also exempt municipalities and their contractors from one-call notification requirements. While DCA supports all efforts to reduce exemptions from one-call and damage prevention statutes, the association believes the 2011 pipeline act stopped short of ensuring ‘shared responsibility’ in damage prevention by not including one-call membership in eligibility requirements for federal pipeline grant assistance. As described above, municipal exemptions to one-call membership compromise damage prevention. All municipal facilities need to be included in the one-call process. Therefore, we believe federal damage prevention grant eligibility requirements should apply the same restriction to state programs exempting municipalities from having to belong to their respective 811 one-call center.

Distribution Contractors Association, (972) 680-0261, http://www.dcaweb.org

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