Grant Piraine
Sep 15, 2022
This guideline was developed to clarify roles, expectations, and risk management practices when performing private utility locates on private property. At the time of writing, there were no consistent regulations, standards, or best practices governing private locates across North America.
This document captures the practical field knowledge required to perform private locates responsibly and safely, and reflects the realities faced daily by excavators, landowners, and private locate service providers.
Introduction
The private locate industry operates much like the old Wild West. There are no specific regulations, guidelines, standards, or best practices governing how privately owned buried facilities should be located and marked prior to ground disturbance. This guideline is intended for anyone who has ever hired a private utility locator and questioned what service is actually being provided, or who is responsible when a buried facility is damaged.
From a technical perspective, public and private locate processes are very similar. The same locate equipment, procedures, and operational requirements are used to trace and mark buried utility infrastructure. However, the process by which public and private locates are requested, supported, and executed differs significantly.
When a locator does not have the necessary tools to perform their job properly, including access, records, or support from the facility owner, the risk of missing or inaccurately locating a buried facility increases. Information management is the primary factor that differentiates public and private locates.
Public locators are provided drawings, records, and access by the public utility owner. Private locators must request this same information from the person who hired them. In practice, private locators are rarely provided utility records or operational support by private landowners. Records may not exist, may be outdated or inaccurate, or the importance of providing them may not be understood. Additional challenges include lack of access to connection points, mechanical rooms, and knowledgeable site personnel.
This guideline was created for excavators, private landowners, and private locate service providers to ensure that all parties understand their role in the private locate process, what information is required, and how risks can be mitigated to reduce facility damage.
Privately Owned Buried Facility Awareness
Prior to performing any ground disturbance, excavators must be aware that privately owned buried facilities may exist within the work area and should be located and marked in advance.
Public utility owners do not mark privately owned buried facilities beyond the demarcation point on private property. Excavators should work with private locate service providers and private landowners to ensure that privately owned buried infrastructure is located and marked prior to ground disturbance.
Private Locates
A private locate should be performed when ground disturbance occurs on private property to locate and mark privately owned buried facilities.
A private locate is performed by a private locate service provider on behalf of the private landowner. These facilities are owned and maintained by the private landowner and are not the responsibility of public utility owners beyond the demarcation point.
When working on private property, the excavator or private landowner should retain a private locate service provider to locate and mark privately owned buried facilities.
Types of Private Utility Locates:
Private Locate With Support
A private locate performed with support occurs when the private landowner provides information regarding their buried utility infrastructure. This includes an inventory of privately owned buried facilities and general location information derived from records or knowledgeable site personnel.
Private Locate Without Support
Private locate service providers are frequently required to work without any support from the private landowner. In these cases, the private locator must identify privately owned buried facilities without records, access, or operational assistance. This significantly increases the risk of missing buried facilities.
When support is not provided, private locate service providers are often contractually bound to third party clients while being perceived as responsible for damages resulting from limitations beyond their control.
Requirements to Perform an Accurate Private Locate
To perform an accurate private locate, the private locate technician requires information that is typically supplied by the utility owner in public locate scenarios. This information should be provided by the excavator on behalf of the landowner, or directly by the private landowner.
At a minimum, the following information is required:
Public locates for the work area
Private landowner utility records
Access to privately owned above ground utility infrastructure
Site operations assistance from the landowner when required
When this information is not provided, the risk of missing a buried facility increases substantially.
Private Locate Methodology
To ensure consistency and accuracy, private locate technicians should follow a defined methodology.
Step 1
Review available records to understand facility paths and connection points. Records may include public locate reports, architectural drawings, construction drawings, as built drawings, and property surveys.
Step 2
Interview site operations personnel to identify potential buried facilities and historical modifications.
Step 3
Visually inspect the work area, building mechanical rooms, and all areas suspected of containing above ground utility structures.
Step 4
Locate buried facilities using a combination of active locating, passive locating, inductive sweeps, and where required, non standard locating methods such as ground penetrating radar or electromagnetic survey equipment.
Step 5
Mark buried facilities using appropriate marking methods including paint, flags, and offset markers.
Step 6
Prepare a detailed private locate report documenting findings and limitations.
Excavator’s Role
When an excavator hires a private locate service provider, they act as a liaison between the landowner and the private locator. Excavators should ensure the private locate technician is provided with:
Public locates for the work area
Private landowner utility records
Access to above ground utility infrastructure
Site operations assistance
Failure to provide this information increases the risk of inaccurate locates.
Private Landowner’s Role
When a private landowner hires a private locate service provider directly, they are responsible for providing:
Public locates for the work area
Utility records
Access to above ground utility infrastructure
Site operations assistance
Private locates performed without this support carry increased risk.
Private Locate Report
A private locate report documents the findings of the locate investigation. At a minimum, it should include:
Client contact information
Site address or location
A drawing depicting buildings, above ground utility structures, and buried facility markings
A limitations section outlining any factors that affected locate accuracy
Documenting Utility Locate Limitations
Any limitation encountered during a private locate must be documented. Limitations increase the risk of missing a buried facility and fall into two categories.
Unavoidable Limitations
Non conductive facilities
Facilities at excessive depth
Angled installations
Missing or non functioning tracer wires
Repairs using non conductive materials
No existing records
Avoidable Limitations
Utility records not provided
Lack of access to buildings or mechanical rooms
No access to connection points
No access to knowledgeable site personnel
Managing Limitations and Special Instructions
When limitations or special instructions are noted on a private locate report, they must be addressed before mechanical excavation begins. Excavators should escalate limitations to supervisors, project managers, clients, or landowners and should not proceed until direction is provided or risk is formally assumed.
Closing Context
This guideline reflects practices developed through decades of field experience in private utility locating and ground disturbance risk management. Many of the principles outlined here later informed broader industry discussions and best practice frameworks. Regardless of jurisdiction, the core principle remains the same: private utility locating is a shared responsibility, and risk increases when roles, information, and limitations are not clearly understood and managed.