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Location of Underground Services Risk Assessment

Location of Underground Services Risk Assessment

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Location of Underground Services Risk Assessment

Product Overview

Identify and control organisational risks associated with the Location of Underground Services through a structured, management-level Risk Assessment that focuses on planning, governance, systems and procurement rather than task-by-task work methods. This document supports executive Due Diligence, strengthens WHS Risk Management and helps demonstrate compliance with the WHS Act while reducing operational and legal liability arising from underground service strikes.

Risk Categories & Hazards Covered

This document assesses risks and outlines management controls for:

  • WHS Governance, Planning and Design Management: Assessment of organisational responsibilities, design-phase service coordination, and integration of underground services risk into project planning and safety management systems.
  • Information Management, Records and Subsurface Data Quality: Management of as-constructed drawings, Dial Before You Dig (DBYD/Before You Dig) data, survey information, version control and accuracy of subsurface utility records.
  • Competency, Training and Accreditation for Service Location: Evaluation of competency frameworks, licensing, verification of competency (VOC), and ongoing training requirements for staff and contractors performing service locating activities.
  • Procurement and Management of Service Location Technology and Providers: Governance of supplier selection, contract conditions, equipment standards, maintenance, calibration and performance monitoring of service locating providers and technologies.
  • Systems for Non‑invasive Service Location and GPR Operation: Protocols for the selection, use and validation of non-destructive locating methods, including ground penetrating radar (GPR), electromagnetic locators and associated operating procedures.
  • Management of Physical Exposure, Potholing and Rerouting of Services: Control of risks associated with test excavations, vacuum excavation, hand digging near services, and planning for service protection, isolation or rerouting.
  • Supervision, Consultation and Communication for Work Near Utilities: Requirements for supervisory oversight, pre-start briefings, consultation with utility owners, and communication pathways between designers, principal contractors and field teams.
  • Risk Assessment, Permit Systems and Authorisation for Ground Disturbance: Implementation of formal ground disturbance permits, service location sign-off, isolation verifications and escalation processes before excavation or penetration works commence.
  • Emergency Preparedness, Incident Management and Reporting for Service Strikes: Planning for gas, electrical, water and communications strikes, including emergency response procedures, notification to authorities, incident investigation and corrective actions.
  • Audit, Review and Continuous Improvement of Underground Services Management: Periodic auditing of service location practices, performance indicators, lessons learned, and continuous improvement of policies, procedures and training programs.

Who is this for?

This Risk Assessment is designed for Business Owners, Project Directors, Construction Managers, Safety Managers and WHS Advisors responsible for planning, approving and overseeing works involving the location of underground services and ground disturbance activities.

Hazards & Risks Covered

Hazard Risk Description
1. WHS Governance, Planning and Design Management
  • • Absence of a documented organisational procedure for locating and exposing underground services prior to excavation or intrusive works
  • • Poor integration of WHS Act 2011 duties into project planning and design phases, leading to inadequate consideration of underground service risks
  • • Design documentation not clearly identifying known or assumed locations of underground services, or not incorporating Dial Before You Dig / Before You Dig Australia (BYDA) data
  • • Lack of clear acceptance criteria for accuracy of non‑invasive service location, ground penetrating radar (GPR) surveys and subsurface mapping outputs
  • • Insufficient consultation between client, principal contractor, designers and utility asset owners regarding underground service information and constraints
  • • No formal process to review and incorporate as‑built information, historical drawings and utility records into the project risk profile
  • • Poor coordination between different contractors performing service location, mapping, and civil works, leading to conflicting or outdated information
  • • Inadequate planning for potential rerouting of existing underground services, including temporary supply arrangements and isolation strategies
  • • Failure to identify and manage cumulative risks where multiple underground utilities and services are co‑located (e.g. gas and HV electrical)
2. Information Management, Records and Subsurface Data Quality
  • • Incomplete, inaccurate or outdated service location drawings leading to incorrect assumptions about underground asset positions and depths
  • • Lack of a centralised system to manage subsurface information from multiple sources (BYDA, as‑built drawings, previous surveys, GPR scans, cable locator outputs)
  • • Poor control over versions and revisions of underground services plans, increasing the risk that field teams rely on superseded information
  • • Insufficient validation or quality assurance of non‑invasive service location outputs (e.g. GPR interpretations, cable locator traces, subsurface mapping) before these are accepted as a basis for decision‑making
  • • Service location reports not being retained, catalogued or linked to specific project locations, preventing future use and lessons learned
  • • Inadequate documentation of areas where service location results are uncertain or where ‘no services found’ has limited confidence
  • • Failure to identify and flag critical risk assets (e.g. high‑voltage cables, high‑pressure gas, fibre backbones) within mapping and GIS systems
  • • No formal process for capturing, updating and distributing verified service location information after physical potholing or exposure
3. Competency, Training and Accreditation for Service Location
  • • Use of untrained or inexperienced personnel to operate GPR, cable locators or other non‑invasive location technologies, resulting in misinterpretation of subsurface conditions
  • • Lack of formal competency requirements or accreditation standards for service locators engaged by the organisation
  • • Insufficient training for project managers, site supervisors and planners on the limitations of non‑invasive service location methods and subsurface mapping
  • • Inadequate awareness among workers and managers about legislative duties relating to underground services under the WHS Act 2011 and WHS Regulations
  • • No structured training in reading and understanding utility plans, GPR output plots, locator markings, and subsurface mapping products
  • • Failure to provide refresher training when new technologies, software or procedures for underground services management are introduced
  • • Limited understanding of specific risks associated with working near utilities and services, including electrical induction, gas leaks, fibre damage and communication outages
4. Procurement and Management of Service Location Technology and Providers
  • • Procurement of low‑quality or unsuitable GPR units, cable locators and related equipment that do not meet industry standards or project requirements
  • • Engagement of third‑party service locators without adequate prequalification, leading to inconsistent quality of non‑invasive service location and subsurface mapping
  • • Lack of clear technical specifications in procurement documents for service location accuracy, reporting format and deliverables
  • • Inadequate maintenance, calibration and verification regimes for GPR, cable locators and other detection equipment
  • • Over‑reliance on a single technology (e.g. only cable locating) rather than using complementary methods (GPR, vacuum excavation) where required
  • • Commercial pressure on service locators to minimise time on site, reducing thoroughness of scans and mapping
  • • No system to review performance of service location providers, including investigation of incorrect or missed service detections
5. Systems for Non‑invasive Service Location and Ground Penetrating Radar Operation
  • • Lack of a standardised process for planning and executing non‑invasive service location surveys prior to excavation or drilling
  • • Inconsistent application of GPR and cable locator methodologies between sites, leading to variable coverage, scan density and data quality
  • • Failure to define survey extents and depths in relation to the proposed works, increasing the chance of services being outside the scanned zone
  • • Inadequate documentation of survey parameters (e.g. grid spacing, frequencies, gain settings, environmental conditions) making future verification and interpretation difficult
  • • No formal validation of GPR interpretations (e.g. through sample potholing) in critical areas, resulting in unverified subsurface mapping
  • • Overconfidence in GPR outputs in ground conditions where GPR performance is known to be limited (e.g. high clay, saturated soils, reinforced concrete)
  • • Poor coordination between non‑invasive locating activities and subsequent physical exposure works, causing misalignment between marked‑up surfaces and actual excavation locations
6. Management of Physical Exposure, Potholing and Rerouting of Services
  • • Inadequate organisational controls around when and how existing services must be physically located and exposed (e.g. potholing) prior to excavation
  • • Lack of a formal decision‑making process to determine when rerouting of existing underground services is required to reduce WHS risk
  • • Poor integration of vacuum excavation and other low‑risk exposure methods into standard work planning, leading to greater reliance on mechanical excavation near services
  • • Insufficient engineering and WHS review of proposed rerouting designs, including temporary bypasses and connections
  • • Weak coordination with utility asset owners when isolation, tie‑ins or diversions are required, leading to uncontrolled changes or outages
  • • Inadequate management of as‑built documentation after rerouting, resulting in outdated records that misrepresent current underground conditions
7. Supervision, Consultation and Communication for Work Near Utilities and Services
  • • Inadequate supervisory oversight of work near identified or suspected underground services
  • • Poor communication of underground service risks and locations to all affected workers, subcontractors and visitors
  • • Lack of structured consultation mechanisms (e.g. pre‑start meetings, toolbox talks) focusing on underground services before and during works
  • • Fragmented responsibilities between client, principal contractor and subcontractors for managing the risks of working near utilities and services
  • • Failure to communicate changes in service information (e.g. updated plans, newly located assets, rerouted services) to all impacted parties in a timely manner
  • • Language barriers or literacy issues that prevent some workers from fully understanding service location plans and mapping outputs
8. Risk Assessment, Permit Systems and Authorisation for Ground Disturbance
  • • No formal permit‑to‑work or ground disturbance authorisation process for activities that may impact underground services
  • • Generic or superficial risk assessments that do not specifically evaluate hazards associated with locating, exposing and working near underground utilities and services
  • • Failure to re‑assess risks when conditions change, such as design modifications, discovery of additional services or changes in work methods
  • • Permits and risk assessments not integrating non‑invasive location data, GPR outputs and subsurface mapping into the decision‑making process
  • • Inadequate linkage between high‑risk work such as directional drilling, piling or dewatering and underground service risk controls
9. Emergency Preparedness, Incident Management and Reporting for Service Strikes
  • • Lack of a specific emergency response plan for underground service strikes, such as gas leaks, electrical contact, water main failures or fibre optic damage
  • • Workers and supervisors not knowing how to respond immediately and safely to an unplanned service contact or exposure
  • • Inadequate arrangements with utility owners and emergency services for rapid response to service strikes or near‑miss events
  • • Failure to report and investigate service strikes and near misses, resulting in repeated systemic failures
  • • No structured process for learning from incidents and updating procedures, training and designs accordingly
10. Audit, Review and Continuous Improvement of Underground Services Management
  • • No systematic auditing of compliance with underground services procedures, permits and legislative requirements
  • • Failure to review the effectiveness of non‑invasive service location methods, GPR use, subsurface mapping and rerouting strategies over time
  • • Lack of performance indicators for managing underground services risks, making it difficult to assess whether controls are improving safety outcomes
  • • Inadequate mechanisms for capturing and sharing lessons learned from different projects and contractors
  • • Complacency or normalisation of deviance, where minor service strikes or repeated near misses are tolerated without systemic improvements

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Legislation & References

This document was researched and developed to align with:

  • Work Health and Safety Act 2011
  • Work Health and Safety Regulations 2017
  • Safe Work Australia – Excavation Work Code of Practice: Guidance on managing risks associated with excavation and trenching, including underground essential services.
  • Safe Work Australia – How to Manage Work Health and Safety Risks Code of Practice: Framework for identifying hazards, assessing and controlling risks in a systematic way.
  • Safe Work Australia – Construction Work Code of Practice: Requirements for planning and managing WHS risks on construction projects, including ground disturbance.
  • AS/NZS ISO 31000:2018: Risk management — Guidelines
  • AS 5488.1:2019: Subsurface utility information – Classification of subsurface utility information for asset and project risk management.
  • AS/NZS 4801 (superseded) / ISO 45001:2018: Occupational health and safety management systems – Requirements for a systematic approach to WHS.
  • Relevant Electricity, Gas, Water and Telecommunications Network Codes: Utility owner requirements for safe approach distances, isolation and notification when working near underground assets.

Standard Risk Assessment Features (Click to Expand)
  • Comprehensive hazard identification for all activities
  • Risk rating matrix with likelihood and consequence analysis
  • Existing control measures evaluation
  • Residual risk assessment after controls
  • Hierarchy of controls recommendations
  • Action priority rankings
  • Review and monitoring requirements
  • Consultation and communication records
  • Legal compliance references
  • Sign-off and approval sections

$79.5

Safe Work Australia Aligned