CGA’s Next Practices Initiative

Legendary management consultant W. Edwards Deming once said, “A system must be managed. It will not manage itself. Left to themselves, components become selfish, competitive, independent profit centers, and thus destroy the system.” And the 811 system is a system like any other in that regard.

In February 2021, Common Ground Alliance’s Next Practices Initiative produced its Report to the Industry. The report has some really interesting ideas for the future but also seems mired in the past in some ways. The report included what CGA calls its three Key Findings:

1.Facilities not marked accurately and on time

The Next Practices committee did some good research on this with a survey of locate technicians that produced some instructive results. Essentially, the techs tell us they are pressured by the area to be marked not being clearly defined, incorrect information provided by excavators and a heavy workload. Locator supervisors say variability and inefficiencies in dig ticket processes make it difficult to staff effectively to meet workloads. Together these issues create pressures that impact safety.

The committee’s research then went further, identifying four factors that drive the locator challenges:

• Increased volume of locates

• One Call transmissions rising despite construction spending staying flat

• Excavator reduced confidence in timeliness of locates resulting in “over-notification”- earlier than necessary 811 calls to ensure that they can dig according to their project schedule

• Locating contracts that are structured around ticket volume rather than safety outcomes

I think the committee’s conclusions are correct. Increased volume of locates and heavy locator workloads? What did you expect? Every 811-system operator in the country has been advertising for years to “Call 811 Before You Dig.” Apparently, the advertising has worked to the point that it has created consumer demand beyond what the service providers can accommodate. I guess that could be part of it.

In reality, it’s about the system and how it has been used and abused by its multiple stakeholders each trying to find an “angle” that lets them meet the requirements of the law at the lowest cost with the least interference in their own operations. The public utilities for the most part, long ago, farmed out their legally mandated locating responsibilities to subcontracted locators. They typically subcontract the work to the lowest bidder and often pay them based on ticket volume. Subcontracting the locating has the added benefit for utilities of having someone else to blame if a locate is late or an inaccurate locate results in a damage case. The contract locators are out there clearing dig tickets as fast as they can with technicians paid the lowest wage possible that will get employees in the door while allowing them to remain the lowest bidder for public utility contracts. And excavators constantly call in as many dig tickets as they can manage to make sure they can keep their crews and equipment moving each day. Oh, and let’s not forget that just as locators are often paid by the ticket, excavators are frequently paid by the foot of fiber, wire or pipe that they install.

Doesn’t that current state of affairs look an awful lot like what Dr. Deming described as what happens in an unmanaged system? Each stakeholder is doing its best to maximize its own outcome.

2.Excavator errors in the field

I’m sorry, but this “Key Finding” is not very instructive, is it? What does that even mean? It’s kind of a catch-all that doesn’t tell us what needs to be fixed. CGA’s Dirt Report says excavators “failing to maintain clearance after verifying marks” is the second most common source of damage. That’s one kind of excavator error, but clearly there must be others.

One more point here is that while excavator errors were the second most common source of damage, the Dirt Report’s most cited cause was “failure to notify” – cases where nobody called 811. So, if I have this right, we have too many 811 calls to handle but the main cause of damage is not enough 811 calls? Maybe there’s some rethinking needed here?

3.Effective and consistent use of 811

Perhaps a more appropriate description would be “Ineffective and inconsistent use of 811.” Unlike their description of excavator errors, the committee gave us some specifics here:

• Locators are not receiving all available information necessary to efficiently locate/mark facilities

• Excavators are often waiting for a site to be marked beyond the required wait time

• Locators are required to respond to a variable workload with a fixed solution

• Excavators have no disincentive to request multiple locates in order to begin a project on time

That first bullet is a good one and it actually has two parts. Excavators often don’t white line or provide specific areas that need to be located. I’ve seen that firsthand at my home where the locators came out to mark my entire lot because a contractor didn’t tell them that they were only going to be putting in a backyard fence. That seems fixable. The second part is that utility owners don’t provide accurate maps. That’s not as easily fixable because often utility maps aren’t created with the locator in mind. They don’t always portray the physical location of the line, but rather provide information the utility operator needs like system connections and age and type of buried assets.

That last bullet though, is the committee saying excavators shouldn’t do whatever works to get their work started on time? It’s not that there’s no disincentive to request multiple locates, it’s that there IS an incentive to do it. They’ve learned that more requests mean they’re more likely to get their locate done on time. And those “paid by the ticket” locators must love getting paid to clear multiple tickets with a single locate.

The Next Practices committee’s report then prescribed what it calls Opportunities for Systemic Improvement with Greatest ROI Potential. These four Opportunities for Systemic Improvement look interesting and some of them reflect the explosion of new technology in the underground locating and mapping world:

• Increase implementation of electronic white-lining

• Pursue a GIS-based mapping system/database

• Utilize technology/software to account for variability in demand (for locates and across the damage prevention process)

• Contractually incentivize adherence to Best Practices and address incidents via effective enforcement mechanisms

Increasing the use of electronic white-lining is a good idea. If a project manager can white line his site from his desktop or tablet, I think he’s more likely to do it. Of course, we may not yet have the technology in place to effectively communicate those virtual white lines to the locator, so that might mean more work and more technology investment for somebody… but who? The work and investments mean real dollars spent by somebody and unless mandated by law, who will volunteer to pay those costs?

Pursuing GIS-based mapping is an excellent idea. Since utilities often don’t have accurate maps of the physical locations of their facilities, someone will have to pay for the technology needed to create, store, edit and distribute mapped data. A few states have started down this road with requirements to GIS locate any new installations, but what about all the stuff that’s already in the ground? It’ll be decades before most of it is replaced and theoretically added to the proposed GIS systems.

Using technology/software to account for variability in demand is a fine idea if somebody invents it. And if it works, you won’t have to include it in any law, regulation, or even Best Practice document. Contract locators especially are always looking for ways to improve their efficiency to make themselves more profitable. They’ll beat down the doors of the software provider to get the tool if it works.

Using contractual incentives and enforcement mechanisms to drive adherence to best practices might be counterproductive. Frankly, there are significant incentives already in place. If an excavator hits a buried facility, he already pays plenty in lost time for workers and equipment, investigations, damage costs and increased insurance premiums. He might even pay a fine if he’s operating outside the law. Prescribing best practices is fine, but how you measure whether they’ve been adhered to can be complicated. It’s often a matter of opinion and you could be creating additional grounds for disputes between utility companies, excavators, locators, and regulators.

CGA’s ideas about increasing the use of technology are outstanding. They really describe steps forward for damage prevention. But I think the idea that these technologies can be retrofitted into the existing system of damage prevention, which was built to comply with current laws is flawed. It’s like saying we’re going to do things a new way while we keep doing them the old way. I think the issues the committee describes in their Key Findings are what the system created by 811 law and regulation have wrought. What we need to do is reinvent that system by taking advantage of all we’ve learned since we started down the damage prevention highway 50 some years ago. To do that, we need to incentivize all the stakeholders because right now the incentives are all driving selfish, competitive, independent profit centers as Dr. Deming described.

Fred LeSage has been a Senior Construction Risk Engineer with AXA XL Insurance since 2011. He assists contractors in the implementation of utility damage prevention techniques. He currently advises AXA XL’s Ecosystem team on damage prevention technologies. Fred can be reached at