Acceptable methods to locate underground utility installations; evaluation of hydro-vacuum excavation.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 7, 2003

Mr. Joseph C. Caldwell
Consultant
Government Liaison
Pipeline Safety Regulations
2111 Wilson Boulevard
Suite 700
Arlington, Virginia 22201

Re: What constitutes an acceptable means of locating underground utilities under 29 CFR 1926.651(b)(2) and (b)(3).

Dear Mr. Caldwell:

Clarification of utility "owner" as used in the Safety and Health Standards for Excavations, Underground Installations.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 21, 2001  [Reviewed May 31, 2018]

Mr. Frank C. DeFelice, Jr.
32 Cherry Lane
Durham, Connecticut 06422

Re: §1926.651(b)(2); utility owners

Dear Mr. DeFelice:

Use of hydro-vacuum excavation equipment and other acceptable means to locate underground utility installions.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 23, 2003 [Reviewed November 22, 2017]

Mr. Joseph Caldwell
Consultant
Governmental Liaison
Pipeline Safety Regulations
211 Wilson Boulevard
Suite 700
Arlington, Virginia 22201

Re: Use of hydro-vacuum or non-conductive hand tools to locate underground utilities; §1926.651(b)(2) and (b)(3).

Dear Mr. Caldwell:

OSHA jurisdiction over oil and gas pipelines may be preempted by DOT standards.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 28, 2004 [Reviewed May 31, 2018]

Ronald J. Gumbaz
Vice President
Delphi Petroleum, Inc.
12 Broad Street
Red Bank, New Jersey 07701

Re: Duty of utility companies or owners to respond under 29 CFR 1926.651(b)(2)

Dear Mr. Gumbaz:

This is in response to your March 16, 2004, fax to the Occupational Safety and Health Administration (OSHA) asking what duties and penalties are incurred by utility companies or owners under 29 CFR 1926.651(b)(2).