As utilities incur third-party damages out in the field, every piece of evidence compiled during the investigation is important to the future recovery of repair costs on that damage. However, a solid photo set, meticulously compiled with a well-thought-out approach is going to be the most critical component, and the sharpest tool you have in protecting your assets through the claims process.
The onus lies squarely with the damaged utility to prove liability with hard evidence. A photo set that utilizes proper elements within will make all the difference in your conversations to recover on a damage claim. If you follow these basic steps to help tell the story when developing a photo set post-damage, the conversation with the liable party will be made much easier.
Assess the damage site prior to taking any photos. While too few is not great, taking photos of everything you see from the time you arrive on site is unfocused and will not allow you to tell a clear story. Take the time to speak to everyone involved and walk the site. Develop the story of what took place and plan your photo approach. Keep in mind that every photo you capture is usable in court.
Always use a hit kit and white paint to highlight the locate marks present and their relationship to the damage point. A handful of “mark” and “damage” pylons along with an oversized ruler made for photos should always be set up to guide the viewer through the photos in terms of locate marks being present and whether they are within the state’s tolerance zone. White marking paint should also be used to circle utility marks on the ground to make them stand out better in the photos. It may be helpful to carry a gallon jug of water for those sites that involve asphalt covered in dirt or dried mud. Some water splashed on the marks will help them pop in your photos, especially on a bright day.
Other tools that are useful in an open excavation are 48” driveway snow poles and a 100’ roll of string with stakes on each end. A pair of the former can be inserted down into the hole six inches apart and the damage or mark pylon placed directly on top of the poles, so the pylon remains visible above the hole and secured. The latter can assist in recreating the continuation of locate marks across an open excavation from each side where they still exist.
Once you have your hit kit and site tools set up, start wide and come from outside of the immediate damage area. Make your way in toward the damage point. Be mindful of where the sun is so you can avoid shadows invading your shots. Find a starting point that includes a unique landscape or identifiable item for that site and take another photo every 10-20 yards as you move toward the damage point, keeping a portion of what was in your last shot in each new shot. This will help the viewer connect the photos. You should also be prepared to flatten the shot a bit by crouching down as needed. The angle of your shot can be critical and shots that always face at a sharp angle toward the ground are generally not the best quality shots.
As you approach the damage point, you should feel good about taking that final shot knowing you have told the story with every shot leading up to that point. Some sites may require the above approach to be followed from two different directions coming in toward the damage, or some follow a “clock approach”, coming at it from all sides. Whatever your approach, be thoughtful and focused, keep the viewer in mind. Ask yourself if it will tell them the story without words to go along with it.
For added protection to your claim, the ability to capture photos of workers or equipment used by the liable party at the time of the damage eliminates an important element of deniability on their end, and every shot taken should have the date and time stamp visible on the photo itself to ensure everyone in the conversation is aware of exactly when the photos took place.
Assess the situation, visualize your approach, set up the scene, and carefully craft a focused set of photos on your damage site that captures all details and eliminates all doubt of what took place, and you will have your most important evidence intact to protect your utility on the back end of a third-party damage.
Troy Hoffman oversees the national damage investigation and recovery division for PRG. He has more than a decade of outside plant damage specific experience, including several years as a damage investigator in the field. He can be reached at firstname.lastname@example.org.