Hydro Excavation and OSHA’s 29CFR1926 Subpart P – Trenching & Excavation
As more and more hydro-excavation projects are being undertaken, it is important to remember that it is more than just a HXX or other hydro-excavator digging a hole and God forbid it’s an Air Mover and Waterblaster. Digging a hole in the ground is always an excavation. As such it is subject to being covered by OSHA’s Subpart P, if certain parameters are met. In fact, OSHA defines an Excavation as such: Excavation: Any man-made cut, cavity, trench, or depression in an earth surface formed by earth removal. A Trench is a linear excavation. Again OSHA’s definition: Trench (Trench excavation): A narrow excavation (in relation to its length) made below the surface of the ground. In general, the depth is greater than the width, but the width of a trench (measured at the bottom) is not greater than 15 feet (4.6 m).

The big deal here is that OSHA requires a Competent Person to be on the job and to make pre-job inspections and additional inspections after any other Hazard Causing Event, such as rainstorms. Water is the number one hazard to trench and excavation stability, and with hydro-excavation, we are using it to make the cut!

For trenching & Excavation OSHA’s definition of a Competent Person is: Competent person: One who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

They MUST have specific training in, and be knowledgeable about: 

• Soil typing & analysis 
• The different kinds of protective systems & their proper use 
• Hazard recognition (including hazardous atmospheres) 
• When a registered P.E. is required 
• Requirements of Subpart P (29CFR 1926)

We offer Competent Person Training in Trenching & Excavation and I urge you to communicate to your customers that they cannot safely or legally use a hydro-excavator without having their people trained. At a bare minimum the competent person(s) must be trained at the ideal, everyone would be trained.

We are able to offer an HXX package that includes both Unit Training and Trenching & Excavation Training.