1926.651(b): Locating Underground Utilities Before Digging
Before opening an excavation, employers must determine the estimated location of underground utilities that may be encountered, and contact utility companies or owners to have them located. If they cannot respond within 24 hours, unless state or local law requires longer, or cannot find the exact location, work may proceed with caution using detection equipment; exact locations must be found by safe means as digging approaches, and utilities must be protected, supported or removed while the excavation is open.
Key takeaways
- 1926.651(b) is part of OSHA's construction standards (29 CFR Part 1926, Subpart P).
- OSHA cited it 125 times in the last 3 years, in 113 inspections, with $409,472 in current penalties.
- 2 deaths are linked to inspections that cited this rule.
- Most citations: OR (32), MD (10), IA (8).
- Related part: 1926.651(b)(4) (49 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1926.651(b) ("Underground installations") is one requirement inside 1926.651 Specific excavation requirements, an OSHA construction standard (Part 1926, Subpart P). It includes 4 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(b) Underground installations. 125 citations
(1) The estimated location of utility installations, such as sewer, telephone, fuel, electric, water lines, or any other underground installations that reasonably may be expected to be encountered during excavation work, shall be determined prior to opening an excavation. Open (b)(1) 32 citations
(2) Utility companies or owners shall be contacted within established or customary local response times, advised of the proposed work, and asked to establish the location of the utility underground installations prior to the start of actual excavation. When utility companies or owners cannot respond to a request to locate underground utility installations within 24 hours (unless a longer period is required by state or local law), or cannot establish the exact location of these installations, the employer may proceed, provided the employer does so with caution, and provided detection equipment or other acceptable means to locate utility installations are used. Open (b)(2) 14 citations
(3) When excavation operations approach the estimated location of underground installations, the exact location of the installations shall be determined by safe and acceptable means. Open (b)(3) 30 citations
(4) While the excavation is open, underground installations shall be protected, supported or removed as necessary to safeguard employees. Open (b)(4) 49 citations
Source: eCFR, text current as of 2026-10-15. Read all of 1926.651.
Injuries linked to this rule
2 deaths are linked to inspections where OSHA cited 1926.651(b).
At 11:30 a.m. on February 28, 2025, Employee #1 and Employee #2 and Coworker #1 and Coworker #2 , were applying CTS Cement Rapid Set Mortar Mix on an exposed fieldstone foundation wall to reinforce the deteriorating wall. The crew was working inside a trench…
Full case list with employer, penalty, filters and download is part of OSHA Data (Purple Belt).
Unlock with Purple BeltWhere and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 13 |
| 2024 | 41 |
| 2025 | 49 |
| 2026 | 22 |
Top states: OR (32), MD (10), IA (8), PA (8), IL (7)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| NELSON PROPERTY SERVICES, INC | BRUNSWICK, ME | $50,938 |
| STEVENS ENGINEERS & CONSTRUCTORS, INC | MIDDLETOWN, OH | $16,131 |
| GRANITE CONSTRUCTION COMPANY | ANCHORAGE, AK | $16,131 |
| REVOLI CONSTRUCTION CO., INC | SOUTH YARMOUTH, MA | $14,188 |
| BLACK ROCK CONSTRUCTION MANAGEMENT, LLC. | BRUCEVILLE, TX | $12,744 |
Free toolbox talk
A 5-minute crew talk on 1926.651(b), plus alerts when this rule changes. Free.
OSHA interpretation letters
- OSHA jurisdiction over oil and gas pipelines may be preempted by DOT standards. (2004-05-28)
- Use of hydro-vacuum excavation equipment and other acceptable means to locate underground utility installions. (2003-10-23)
- Acceptable methods to locate underground utility installations; evaluation of hydro-vacuum excavation. (2003-07-07)
- Clarification of utility "owner" as used in the Safety and Health Standards for Excavations, Underground Installations. (2001-09-21)
Related parts of this rule
- 1926.651(b)(4) 49 citations
- 1926.651(b)(1) 32 citations
- 1926.651(b)(3) 30 citations
- 1926.651(b)(2) 14 citations
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Frequently asked questions
Do I have to locate utilities before digging?
Yes. The estimated location of underground installations must be determined before opening an excavation.
What if the utility company does not respond?
If they cannot respond within 24 hours, unless a longer period is required by state or local law, or cannot find the exact location, the employer may proceed with caution using detection equipment or other acceptable means.
What happens when digging gets close to a utility?
The exact location must be determined by safe and acceptable means.
About this page
Sources
- 29 CFR 1926.651 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-19
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.