Pipeline safety operational ownership depends on recognizing abnormal operating conditions and acting in accordance with your training and OQ plan before work continues. Operators and contractors must understand that anyone has the responsibility and authority to call a safety stop whenever conditions are unclear, unexpected, or inconsistent with the work package. Never assume the documentation provided is complete. Perform due diligence by checking all available sources, such as company specific documentation software, GIS records, and archived paper files to confirm that the correct records have been reviewed. If information is missing or cannot be verified, stop working and resolve the issue before proceeding.

Description of Event

While excavating a trench for a gas main installation, a second-party contractor crew operating with a valid 811 ticket struck an unmarked 0.5-inch plastic gas service stub. The stub previously supplied a service that was retired prior to demolition of the premises that previously held the property address number. Following the incident, a retirement card for the service was located in the system, and the retired line was also represented in the GIS database. However, the locator reported that the retirement card had not been included in their work packet.

Root Causes and Contributing Factors

• Primary Causal Factor: Locator binder lacked necessary information/details (available stub service card missing).
• Root Cause(s): Management System – SPAC Not Used Management System – Oversight/Employee Relations – Infrequent Audits & Evaluations Management System – Oversight/Employee Relations – Audits & Evaluations Not Independent
• Secondary Causal Factor: After job hand off, new locator did not call safety stop when receiving incomplete locator binder (incomplete binder is AOC).
• Root Cause: Management System – SPAC Not Used

Key Corrective Actions

Contractor to implement monthly audits on their Locator Binders that will be provided to Operator for review. Audits will be done for all current and scheduled upcoming work and be conducted by a subject matter expert vetted and approved by Operator Contractor will create internal Standard Operating Procedure on their locating process and submit it to Operator for review/approval. During next all hands call with contractor, Operator will highlight the importance and the responsibilities of calling a safety stop if any abnormal operating condition arises during any stage of their work.

Key Lessons Learned

Make sure all necessary paperwork and documentation is being supplied to complete the job. Do not assume you have all proper documentation, do your due diligence to investigate and confirm if documents are available (electronic documents, GIS, and paper copies in barns).

Due diligence steps for verifying documents:

1. Review the work packet for required maps, service records, retirement cards, permits, and job-specific instructions.
2. Compare the documents with the field conditions and confirm addresses, asset locations, pipe sizes, materials, and statuses match.
3. Search all available record sources, including document management software, GIS, archived paper files, and local facility records.
4. Check for missing, conflicting, outdated, or incomplete information, especially after a job handoff.
5. Contact the operator or appropriate subject matter expert to resolve discrepancies and confirm the current record set.
6. Document the verification and any additional records obtained.
7. Call a safety stop if required documents are missing or information cannot be confirmed; do not proceed until the issue is resolved.

Documentation, Documentation, Documentation !!!!

Regulatory and Safety Context

In regulated industries, “traceable, verifiable, and complete” (TVC) records are required to ensure accountability and safety. For example, the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) mandates TVC records for pipeline assets, including pipe mill data, as‑built documents, and other physical property records that can be linked to the original source