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Potential Changes on the Horizon at the Texas Railroad Commission

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During December 2011, the Texas Railroad Commission held a series of stakeholder outreach events to discuss potential changes to Chapter 18 of the Texas Administrative Code which establishes the authority of the Texas Railroad Commission to regulate excavation and conduct damage prevention enforcement activities related to underground pipelines that convey natural gas. During these meetings, the Railroad Commission unveiled the proposed changes in an upcoming proposed rule, which could mean changes in the way you dig. AGC members actively participated in these discussions sharing the “professional excavator’s” viewpoint on several key items.

This gave AGC members the opportunity to lay it all out on the table and discuss how to accomplish truly effective damage prevention. Layers upon layers of rules are not the solution, and can potentially create more confusion and safety issues. Fortunately, AGC of Texas has a longstanding reputation of working with the Commission and other stakeholders to promote a common sense approach to damage prevention. AGC of Texas asserts that true damage prevention is a shared responsibility requiring the participation of all stakeholders—not just the contractor.

As professional excavators, Chapter members realize that effective damage prevention is more than just following the rules, it is part of a larger culture of safety. We want our people to come home safe at the end of the day and we want a successful project. The existing rules clearly dictate what steps an excavator must take, including calling 811 to locate facilities, waiting the required forty-eight hours to commence excavation activities and digging with care. Most of us are aware that there are a number of other requirements in between and after these steps, such as refreshing tickets and reporting damages when they occur. What we must continue to stress with the damage prevention community and the Railroad Commission is how to accomplish true damage prevention. The real challenge and key to performing a safe and successful excavation project starts with accurate and timely located Potential Changes on the Horizon at the Texas Railroad Commission and marked underground facilities.

Unfortunately, many facility owners do not know where or how deep their pipes are, which presents a significant safety issue for excavators. As you peel back the layers of this onion, it becomes readily apparent that liability weighs heavily on the motivations of all stakeholders. Our job as contractors is to use extensive experience to move beyond the finger pointing into real progress for safety and damage prevention.

A few key items that the Railroad Commission and stakeholders discussed in the December meetings included updating and clarifying the definition of the tolerance zone, white lining requirements, ticket life and length, establishing protocols and marking guidelines. AGC members shared our views on all of these topics and more and made additional recommendations such as requiring RFID balls to ensure accurate as-builts and requiring vertical locations based on elevation.

Meaningful damage prevention does not require a new regime of rules accounting for every possible scenario. The Commission would benefit more by applying common sense and streamline existing rules. It is highly unlikely that the Railroad Commission rules can account for or prevent some yahoo working out of the back of a truck digging fence posts who neither calls for a locate nor follows the rules once dirt starts to turn. As the representative of professional excavators, AGC will continue to share the views of the professional excavator community promoting a process that is fair, consistent and reasonable.

The Commission will likely unveil the proposed rule this summer and the good news is that your fellow members and staff in Austin will be there every step of the way!

Remember to call 811 and dig safely!

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