Strengthening Damage Prevention: PHMSA Pushes Operators Toward More Aggressive Excavation Risk Management

In its latest advisory tied to National Safe Digging Month, PHMSA is reinforcing a familiar message with sharper operational expectations: excavation damage remains one of the leading threats to pipeline safety, and operators need to tighten coordination, improve locating accuracy, and treat even “near-miss” events as integrity threats.

ADB–2026–05 does not introduce new regulatory requirements, but it clearly signals where PHMSA expects operators to raise their game—particularly in locator performance, stakeholder coordination, and post-damage response.

Why This Matters

Excavation damage continues to be a top cause of pipeline incidents across both gas and hazardous liquid systems. What stands out in this advisory is PHMSA’s focus on execution quality, not just program existence.

Most operators already have damage prevention programs, 811 participation, and public awareness efforts in place. This bulletin goes further, emphasizing:

• Adoption of Common Ground Alliance (CGA) best practices, specifically focusing on accuracy of locating and rapid response to strikes
• Enhanced locator training and oversight
• Proactive White Lining
• Speed and effectiveness of response to strikes
• Integrity verification after near-misses
• Public awareness that actually drives behavior change

PHMSA is also reminding operators of existing regulatory obligations under 49 CFR §§ 192.613 and 195.401, reinforcing that third-party excavation risk is a core component of required surveillance activities—not a standalone program.

Key Takeaways for Operators

1. Move Beyond Compliance to Precision in Locating

PHMSA is explicitly pointing operators to CGA Best Practices. These Best Practices are available at: https://bestpractices.commongroundalliance.com/1-Introduction/102-History-of-the-Common-Ground-Alliance

Operational implication:
This is a clear expectation that operators validate not just that locates are performed—but that they are accurate, timely, and reliable.

Operators should consider:

• Auditing locate accuracy rates (not just completion metrics)
• Evaluating tolerance zone practices
• Reviewing damage history tied to mis-locates

2. Increase Training and Oversight of Locators

PHMSA is signaling concern around locator performance - particularly in high-growth areas.

Action items:

• Review and enhance training of internal and contractor locators
• Audit both internal and third-party locators
• Ensure adequate time, staffing, and tools for accurate marking
• Focus oversight on regions with heavy construction activity

This is an area inspectors are likely to probe - especially where contractor locators are used extensively.

3. Push Pre-Construction Coordination Upstream

The advisory highlights two underutilized but high-impact practices:

• “White lining” excavation areas
• Pre-construction meetings for large projects

Operational takeaway:
Operators should:

• Engage earlier in project planning
• Encourage excavators to white line proposed dig areas
• Ensure excavators understand depth, pressure, and emergency protocols

4. Rethink Public Awareness Programs

PHMSA is clearly raising expectations for public awareness effectiveness - not just outreach volume.

Key enhancements suggested:

• Expand beyond traditional communication channels
• Provide clear, actionable guidance (not generic messaging) on recognizing and responding to pipeline releases
• Use performance metrics to evaluate effectiveness
• Incorporate incident data and stakeholder feedback

Notably, PHMSA calls out:

• The need to raise awareness in areas with one-call exemptions
• The importance of educating the public on how to recognize and respond to a release

This aligns with broader regulatory trends pushing operators toward measurable program effectiveness, not just compliance documentation.

5. Treat “Near Misses” as Integrity Threats

One of the strongest operational signals in this advisory:

If a pipeline is struck or scraped—even without a leak—conduct a thorough inspection.

Implication for integrity management:

• Mechanical damage can create latent defects
• These defects may evolve into future stress corrosion cracking or delayed failure

Operators should ensure:

• Clear procedures for post-strike evaluation
• Integration of these events into IM/DIMP/TIMP risk models
• Documentation and tracking of “non-leak” damage events

6. Strengthen Patrol Effectiveness

PHMSA reinforces the role of patrols as a frontline defense against excavation damage.

Expectations include:

• Identifying unauthorized or unsafe excavation activity
• Rapid follow-up on ROW encroachments
• Ensuring through field observations that excavation activity does not pose a threat to the pipeline

Regulatory Signals to Watch

Several themes in this advisory point to where PHMSA may focus inspections and future rulemaking:

• Locate accuracy as an enforcement target
  Expect more scrutiny on how operators validate and audit locating performance - not just whether tickets are closed.
• Contractor oversight
  Increasing emphasis on accountability for third-party locators and excavators, including verification of adequate training.
• Program effectiveness metrics
  Public awareness and damage prevention programs may be evaluated based on outcomes.
• Integration with integrity management
  Near-misses, strikes, and excavation activity are being framed as data inputs into IM programs, not isolated events.
• States with one-call exemptions
  This could signal future regulatory attention or coordination efforts where gaps exist in excavation notification requirements.

Final Takeaway

ADB–2026–05 is less about new requirements and more about raising the standard of execution across damage prevention programs.

The message is clear:

• Accurate locates matter more than completed locates
• Near-misses matter as much as incidents
• Public awareness must drive behavior - not just check a box

For operators, this is a good time to step back and ask a hard question:

Is your damage prevention program truly reducing risk in the field - or just meeting minimum expectations on paper?