In the underground construction world — from the owner, to the engineer, contractor and sub-contractor — everyone is responsible for damage prevention. In Canada, the unifying voice for underground infrastructure damage prevention is the Canadian Common Ground Alliance (CCGA).
Unlike its neighbor to the south, the Common Ground Alliance, the CCGA is an association of associations rather than individual member companies. Though the makeup is a little different, the overall goal is the same: creating and advocating for damage prevention practices across Canada that ensure public safety and increase the integrity and reliability of the nation’s underground infrastructure.
“Our desire is to attract associations that have an interest in underground infrastructure and safety like the Canadian Energy Pipeline Association [CEPA], Canadian Gas Association, Canadian Association of Pipeline and Utility Locating Contractors, the Canadian Construction Association and the regional partners of the Common Ground Alliance,” says Mike Sullivan, CCGA executive director. “In this sense, our reach is far greater than it could ever be. We estimate our reach is about 1.5 million Canadians.
The Common Ground Alliance initiative started in Ontario in 2003 and additional regional partners emerged in British Columbia (BC), Alberta and Quebec. Over the span of a decade, regional partners of the Common Ground Alliance emerged in all of the provinces working on regional safe digging and damage prevention matters.
Though the different alliances did communicate with one another, it became evident that there were certain areas where damage prevention and safe digging needed a national approach. That discussion progressed and the CCGA got its start as a virtual committee with representation from the regional partners.
“We would discuss matters of national interest and put task forces together as necessary to address and complete those issues and it ran like that for some time,” Sullivan says. “This led to 2010 and the drive to bring three-digit dialing, or 811, to Canada.”
The CCGA received more than 200 letters of support and petitioned to have joint availability of Call 811 in Canada. A scenario, that if adopted, would mean a caller would dial 811 and select 1 for health services and 2 for locate requests. The request was denied, and work was afoot to create a new call to action. “811 was already allocated to non-emergency health services but that project brought so many interested stakeholders together that we had to do something more,” Sullivan says. “We couldn’t ignore the clear desire for a national damage prevention approach.”
It worked out well for the group that the federal request was denied because more and more, the digging community was submitting locate requests online.
“We secured ClickBeforeYouDig.com and built a website in English and French. The site was simple — a map of Canada where you clicked on the province you are working in and began the locate request online,” Sullivan says. “The web locate request process allows a person to include attachments to the request which could be a Google map, photograph, a sketch or anything that further explains the area of excavation. These attachments reduce the amount of interpretation that occurs in the field so this really helps enhance the integrity of the damage prevention process.”
Very quickly, ClickBeforeYouDig.com became Canada’s damage prevention call-to-action — like Call 811 in the United States. This led to the formalization of the CCGA in 2011. Instead of being a virtual committee with eight members, it quickly expanded to a 25-member board of directors, covering a variety of areas of the damage prevention process from major transmission pipelines to regulatory agencies like the National Energy Board (NEB).
In addition to ClickBeforeYouDig.com, the CCGA has undertaken several initiatives to improve damage prevention across the nation. The first to be completed was a harmonization of damage prevention best practices into a nationally-accepted manual. The CCGA released “Underground Infrastructure Damage Prevention Best Practices – Version 2.0” in 2016 in both English and French.
“When the first regional partners of the Common Ground Alliance began to appear in Canada, the Ontario Regional Common Ground Alliance [ORGCA] created the best practices for Ontario. BC and Québec evolved theirs from the ORCGA’s. There was a concern that the regional partner best practices were migrating apart and would continue to do so,” Sullivan recalls. “When the CCGA came together as an organization, we recognized that we needed to harmonize the best practices to benefit the digging community and to have a much more solid influence on damage prevention across Canada.”
As Version 1.0 of the manual was put together the CCGA was asked to chair a Canadian Standards Association technical committee charged with creating a damage prevention standard for Canada. Those efforts began in 2013 and the CSA standard — CSA Z427 Code — was published in May 2015. On April 1, 2017, the standard was incorporated via reference by the Technical Standards and Safety Authority in Ontario.
“This was one of the largest technical committees ever assembled to create a CSA standard and I am proud of what the committee was able to accomplish,” Sullivan says. “From A-Z, it fulfills our objective to provide a standard, created by a committee of varied underground infrastructure backgrounds, that everyone can live with.”
He adds that when a CSA Standard is incorporated by reference, in whole or in part, the Standard becomes law and from what he has heard from the regional partners, incorporation by reference by other regulators is likely.
On the federal level, the CCGA is nearing another significant milestone as Senate Bill S-229 “Underground Infrastructure Safety Enhancement Act” makes its way through the Senate. Sponsored by Sen. Grant Mitchell, of Alberta, S-229 will govern damage prevention for all federally regulated underground infrastructure or any underground infrastructure situated on federal lands.
According to Sullivan, who is actively testifying on the CCGA’s behalf as the bill makes its way through committee, there is close to 200,000 km of transmission pipelines across Canada and likely well over 1 million km of telecommunications networks. Add to that railways’ signals and communications, underground infrastructure on government-owned land — all of it falls under this regulation.
“While the bill demands that all federally regulated underground infrastructure, and underground infrastructure on federal lands, register with a notification centre, there’s a lot more to it than that,” Sullivan says. “The bill is reciprocal in that it requires any person digging to request a locate of these underground utilities which effectively triggers the damage prevention process.”
Across Canada in 2015, 33 per cent of all damages to underground infrastructure didn’t have a locate request. In other words, according to Sullivan, the damage prevention process never had a chance to begin or be effective.
“We are focusing on the federal side and the goal is that the language we drafted for this senate bill once it is passed could be picked up by the regional partners of the Common Ground Alliance and applied in their respective provinces,” Sullivan says. “It would have to go through the entire process in each province, but the drafting and language will be done. To achieve effective damage prevention governance that meets public expectations, we need symmetrical governance across the country.”
In June 2016, the NEB released its new Damage Prevention Regulations replacing an almost 30-year-old regulation known as the Pipeline Crossing Regulations. This is the only other federal regulation governing damage prevention and it is strictly transmission pipeline oriented.
The new regulations require pipeline companies governed by the NEB to register with a one-call system. Prior to the update, the mandatory registration language did not exist, though Sullivan, who worked with the NEB as an inspection officer for 10 years, notes the vast majority of NEB-regulated pipelines owners were registered with One-Call systems.
The Cost of Damages
A key component to getting elected officials on board with federal and provincial underground infrastructure damage prevention legislation comes down to dollars and cents. It is easy to say to someone that it costs $5,000 to repair a section of pipe that was damaged during a dig, but factoring in societal costs and that number balloons to an eye-popping amount.
Using data from the DIRT report — the report generated annually from the Common Ground Alliance’s Damage Information Reporting Tool (DIRT) that monitors underground infrastructure hits — the CCGA commissioned Centre for Interuniversity Research and Analysis of Organizations (CIRANO), to develop a societal cost formula. When applied to DIRT data, the formula would provide a defendable estimate of the costs society bears in relation to damaged underground infrastructure.
In 2015, the year most recent data was available, damages to underground infrastructure cost Albertans an estimated $300 million. Extrapolated across the country, Canadians are conservatively looking at more than $1 billion in damages.
“When we are talking about this legislation, we can’t expect everyone to understand the effect of damage beyond the most catastrophic event that appears in news feeds so we needed to develop some concise messaging that we could use when speaking with a politician, regulator or any other interested part,” Sullivan says. “The question we get is, ‘ What does that mean and how did you get to that cost?’ When you start explaining it, people realize that the numbers make sense. The smallest cost is usually the repair itself.”
Sullivan further explains that, for a damaged gas line, a city block might be evacuated, businesses in that block get shutdown and households displaced. A single fire truck might cost $5,000 an hour to run and at least one truck will be there for half of the day. In addition to that there are costs associated with injuries, traffic deviation, clean up, etc. — and that’s when the event doesn’t result in a fire.
At this point, all eyes in the underground infrastructure damage prevention world are on S-229. As that moves through the process the provinces are taking note and Sullivan expects provincial legislation is likely in BC, Alberta, Saskatchewan and Quebec where regional partners of the Common Ground Alliances are already working towards the goal.
Given the estimated reach to 1.5 million Canadians, just how many are listening? On a local level, as president of Alberta One-Call Corp., Sullivan says people are more aware of safe digging.
“Alberta One-Call is the oldest system in Canada [established in 1984] and one of the oldest in North America. There is a great awareness of safe digging because the transportation of hydrocarbons is the economic driver for the province,” Sullivan says. “Awareness in general is difficult to gauge and it depends who you ask. In terms of digging community, they are more aware now because of presence and active engagement of the regional partners of the CCGA.”
Data from the ClickBeforeYouDig.com website indicate that the safe digging message is getting out as traffic to the site increases each year. Because some of the regional association members — like TransCanada and Enbridge — work on both sides of the border, the website has been expanded from a map of Canada to a map of North America.
“There will always be pockets where people are more aware, but if you are a diligent contractor, you will always be at the leading edge of safety,” Sullivan says. “In Alberta, for example, when Alberta One-Call transferred its call-to-action from Call Before You Dig to Click Before You Dig five years ago, we went from about 30 per cent of the locate requests we received annually being online to 85 per cent online.”
Growing alongside ClickBeforeYouDig.com is DigSafeCanda.ca. Where ClickBeforeYouDig.com is a portal for beginning locate requests the Dig Safe Canada website is the educational and public relations outreach arm of the CCGA.
“Our society has no idea on whole of just how much we rely on underground infrastructure or of the corporate, provincial and national efforts to maintain and enhance the integrity of that infrastructure. The minor inconvenience a person might feel when they turn on a light switch and the light does not go on is nothing compared to what can happen if you take out a fibre optic line to an entire community, or hospital or 911 service yet it happens and it continues to happen,” Sullivan says. “We are at a point now where we almost can’t function without these services. If we can’t function, nothing gets done, so this has a major impact on our economy, our day-to-day life and livelihoods.”