
FREQUENTLY ASKED QUESTIONS
Understanding Private Locating, Risk, and Responsibility
FOUNDATION: ROLES AND DEFINITIONS
What is a Private Locator?
A Private Locator locates buried utility infrastructure on private property or beyond the public utility demarcation point. This includes facilities not covered by One Call or 811 systems. The Private Locator operates at the execution phase of a project, where site conditions are uncertain and buried infrastructure must be confirmed in the field.
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What is a Damage Prevention Specialist (DPS)?
A Damage Prevention Specialist is the field level risk manager responsible for interpreting locate information, identifying limitations, and guiding safe ground disturbance decisions. This role brings together public locates, private locates, site conditions, and project scope into one operational picture.
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This role is often performed by a Private Locator, particularly on complex sites where locating and risk interpretation occur together. However, the role is not limited to locators. A Damage Prevention Specialist may also be a project manager, supervisor, or site representative who does not perform locating but is responsible for managing risk at the point of ground disturbance.
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What is Buried Utility Infrastructure / Facility / Plant / Utility Line?
A cable, line, pipe, conduit, or structure used to gather, store, or convey products or services. Sometimes incorrectly referred to as "utilities".
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What is a Utility Owner / Utility Company / Landowner?
Any entity, including a municipality, authority, or private company, that owns, operates, or controls the operation of buried utility infrastructure or facilities.
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What is Ground Disturbance?
Any activity that disturbs or displaces soil or ground cover, including but not limited to:
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Digging, trenching, ditching, tunneling
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Boring, drilling, augering, pushing
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Plowing to install underground infrastructure
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Tree planting, clearing, stump removal
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Blasting, quarrying, seismic exploration
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Driving fence posts, anchors, or pilings
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Crossing buried pipelines or underground infrastructure with heavy equipment
PROJECT LIFECYCLE AND INDUSTRY STRUCTURE
Where does NAPUA fit in the project lifecycle?
NAPUA focuses on the execution phase of the project lifecycle. This is the point where design and assumptions meet field reality and where damage risk is highest. NAPUA provides structure and guidance for this phase, which has historically operated without a unified framework.
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What is the difference between public and private locates?
Public locates identify buried utility infrastructure owned by utility companies up to the demarcation point and are delivered through regional One Call or 811 notification centers and delivered by public locate companies or their locate company representatives.
Private locates address infrastructure beyond that demarcation point, including privately owned facilities and site specific systems not captured through public locate processes.
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Why is there a gap in private locating?
Public locating is regulated and standardized across jurisdictions. Private locating has developed independently without consistent definitions, expectations, or delivery standards. This creates variability in quality, communication, and risk management at the point where ground disturbance occurs.
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Does NAPUA replace One Call or 811 systems?
No. One Call systems remain the regulatory entry point for public utility locates. NAPUA does not replace that process. It addresses how buried utility infrastructure is understood, verified, and managed at the execution phase of a project, on both public and private property.
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While public locates establish the baseline, additional investigation is often required in the field. Private locators may be engaged to verify public locate markings, investigate discrepancies, or identify additional infrastructure not captured through the One Call process, including within the right of way.
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What should I expect from a private locate?
A private locate is a best effort investigation based on available information and site conditions. It does not represent a complete or guaranteed identification of all buried utility infrastructure. The outcome is information and documented limitations that define the risk for the project, not permission to proceed.
FIELD APPLICATION AND RISK MANAGEMENT
Why are private locators critical at the execution phase?
Public locates provide a starting point, not a complete picture. They rely on available records and standard detection methods, both of which have limitations.
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Private locators operate at the execution phase, where those gaps must be addressed in the field. In many cases, they also take on the role of the Damage Prevention Specialist by interpreting locate information, identifying limitations, and helping define the risk before ground disturbance begins. They verify public locate markings, locate privately owned utility lines, and document the conditions that drive decision making. This is where field conditions are understood and where damage is either prevented or created.
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What issues impact a private locate before work begins?
​Most challenges occur before the locator arrives on site. Missing utility records, lack of access to buildings or appurtenance connection points, no knowledgeable site contact, and poorly defined work scope all reduce the effectiveness of the locate. When these conditions exist, the locate is limited before it starts.
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What happens when key information is missing?
The locate becomes incomplete by condition. Critical buried utility infrastructure may not be identified, limitations increase, and uncertainty shifts to the execution phase. At that point, the Ground Disturbance Professional is making a risk based decision rather than working from confirmed information.
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What is a limitation on a locate?
A locate limitation is any condition that prevents a complete or reliable identification of buried utility infrastructure. This includes missing records, lack of access, non traceable facilities, signal interference, or unknown installations. A limitation is not just a note on a report. It is a direct indicator that risk is present and must be managed before work proceeds.
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What separates a strong locate from a weak one?
​A strong locate includes utility records review, full site access, identification of above ground structures, engagement with site personnel, and clear documentation of limitations.
A weak locate relies on surface level scanning with little investigation, limited access, and minimal documentation. The difference directly impacts the level of risk carried into the project.
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How should limitations be managed?
Limitations should be identified, communicated, and incorporated into the ground disturbance plan. Typical responses include controlled exposure, adjusted work methods, and increased supervision at the point of excavation.
Can all buried utility infrastructure be located?
No. Certain facilities cannot be detected due to material type, installation method, or site conditions. This reinforces the need for a risk based approach rather than reliance on markings alone.
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What if a buried utility line cannot be located?
​If a facility cannot be located, it should be treated as a potential conflict. The work area should be managed as a critical zone, and the plan adjusted to account for uncertainty. This may include redefining the work method, using controlled exposure techniques, and proceeding with increased caution. The absence of a locate does not confirm absence of infrastructure. It confirms uncertainty.
What should be done before hiring a private locator?
All available utility records should be gathered and provided. Access to buildings and tie in points should be arranged. A knowledgeable site contact should be identified, and the work scope clearly defined. The quality of the locate is directly influenced by the information and access provided before the work begins.
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What does a private locator actually provide?
A private locator provides information to support decision making at the point of ground disturbance. This includes locating privately owned detectable buried utility infrastructure, verifying existing markings, investigating site conditions, and defining limitations.
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The deliverable should be provided in the form of a report supported by a drawing or site reference that reflects what was identified, what could not be confirmed, and the limitations encountered. It should clearly communicate the level of confidence in the information and the areas where risk remains.
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The output is not a clearance. It is a defined level of risk that must be understood, accepted, and managed before work proceeds.
ROLES, RESPONSIBILITIES, AND DECISION MAKING
Who is responsible for preventing utility damage?
Responsibility is not assigned up front. It is determined after a damage investigation based on what each party knew, what they were provided, and how they acted.
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Utility owners, locators, and landowners are responsible for the accuracy and completeness of information. The Ground Disturbance Professional is responsible for how the work is carried out in the field. When damage occurs, liability follows the point where that process failed.
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What is the role of the Ground Disturbance Professional (GDP)?
The Ground Disturbance Professional is responsible for planning and executing the work. This includes understanding locate information, recognizing limitations, and selecting appropriate methods of excavation or drilling.
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This role typically includes contractors and field personnel such as excavators, drillers, equipment operators, foremen, hand diggers, field technicians, and site supervisors. It may also include project managers or engineers when they are directly responsible for how the work is planned and carried out in the field.
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Can a private locate confirm that an area is clear?
No. A private locate provides information, not confirmation of absence.
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Only SUE Level A methods (visual confirmation) can confirm the exact position of a buried facility. All other locate methods carry limitations that must be understood and managed before work proceeds.
TRAINING AND STANDARDS
Does NAPUA provide training?
NAPUA establishes the framework for training and certification. Training programs are delivered through aligned providers and structured to support consistent understanding across the industry.
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Why is standardization important in private locating?
Without standardization, outcomes depend on individual experience and company practices. A structured approach improves consistency, communication, and overall safety performance across projects.
NAPUA’S ROLE
What does NAPUA provide to the industry?
NAPUA provides a structured framework for private utility locating and execution phase risk management. This includes definitions, guidance, and alignment across stakeholders operating on private property.
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Who is NAPUA for?
NAPUA supports:
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Private locators
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Ground disturbance professionals including engineers and project planners
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Property owners and asset managers
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Engineers and project planners
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Insurers and risk professionals
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Legal construction professionals
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How is NAPUA different from other organizations?
NAPUA focuses specifically on private property and the execution phase of work. Other organizations address design or public locate systems. NAPUA addresses the point where work actually occurs and where damage risk becomes real.
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What is the objective of NAPUA?
To bring structure to the execution phase of ground disturbance and ensure that all stakeholders operate with a shared understanding of risk, roles, and responsibilities around buried utility infrastructure.
CALL TO ACTION
Ready to reduce damages and bring clarity to private-property ground disturbance?
Join NAPUA and work within a national framework that supports ground disturbance professionals across North America.