OSHA 1926.651(b)(1): locating underground utilities before digging
Under 29 CFR 1926.651(b)(1), the estimated location of sewer, telephone, fuel, electric, water and other underground installations that may be encountered must be determined before an excavation is opened, and utility owners must be contacted and asked to locate them.
Official text
(b)(1) The estimated location of utility installations, such as sewer, telephone, fuel, electric, water lines, or any other underground installations that reasonably may be expected to be encountered during excavation work, shall be determined prior to opening an excavation.Read the full section on eCFR
(b)(2) Utility companies or owners shall be contacted within established or customary local response times, advised of the proposed work, and asked to establish the location of the utility underground installations prior to the start of actual excavation. When utility companies or owners cannot respond to a request to locate underground utility installations within 24 hours (unless a longer period is required by state or local law), or cannot establish the exact location of these installations, the employer may proceed, provided the employer does so with caution, and provided detection equipment or other acceptable means to locate utility installations are used.Read the full section on eCFR
(b)(3) When excavation operations approach the estimated location of underground installations, the exact location of the installations shall be determined by safe and acceptable means.Read the full section on eCFR
What it requires, in plain English
- The estimated location of underground utilities that may reasonably be expected is determined before the excavation is opened.
- Utility companies or owners are contacted within customary local response times and asked to locate their installations before digging starts.
- If they cannot respond within 24 hours, unless state or local law allows longer, or cannot establish exact locations, work may proceed with caution using detection equipment or other acceptable means.
- As digging approaches the estimated location, the exact location is found by safe and acceptable means.
Where it shows up on site
- An excavator digging with no locate marks on the ground
- Faded or partially destroyed paint marks from an old locate
- Machine digging directly over marked lines instead of exposing them by hand or vacuum
Verify on site before you call it
A photo rarely shows every fact a standard depends on. Confirm these in person before treating the condition as a violation:
- Was a locate requested, and what is the ticket date and scope?
- Do the marks cover the full area being dug, and are they still visible?
- How close is the digging to the marked lines?
- What method is being used to expose the lines as digging approaches them?
Typical corrective actions
- Stop digging until the estimated utility locations are confirmed for the work area.
- Request or refresh the utility locate and wait for marks before resuming.
- Expose lines by safe and acceptable means, such as hand digging or vacuum excavation, as work approaches them.
- Protect, support or remove exposed installations while the excavation is open.
Common questions
Does OSHA require calling for utility locates before digging?
Yes. 1926.651(b)(2) requires that utility companies or owners be contacted within established or customary local response times, advised of the work, and asked to locate their underground installations before excavation starts.
What if the utility company does not come out to mark the lines?
If they cannot respond within 24 hours, unless state or local law requires a longer period, or cannot establish exact locations, the employer may proceed with caution, provided detection equipment or other acceptable means are used to locate the installations.
Turn the observation into a notice
Record what the photo shows, confirm the on-site checks above, and identify the responsible company and due date. Use the fillable construction safety notice template or follow aworked example from observation to verified fix. Cirqify can draft the notice from your circled photo for you to review.
Related standards
This guide summarizes federal OSHA construction standards for general information. It is not legal advice. States with their own OSHA-approved plans may set different or additional requirements; see federal and state coverage.