Safety Advisory SA 2025-02 – Safety and Damage Prevention Practices related to Large Scale Projects Near Pipelines

Safety Advisory SA 2025-02 – Safety and Damage Prevention Practices related to Large Scale Projects Near Pipelines [PDF 241 KB]

File 6653583
6 October 2025

Please find attached Safety Advisory SA 2025-02.

The Canada Energy Regulator (CER) expects regulated companies to demonstrate a proactive commitment to continual improvement in safety, security, and environmental protection, and to promote a positive safety culture as part of their management systems.

Preventing damage to pipelines is a responsibility shared by CER-regulated pipeline companies, third-party project owners with projects near pipelines, and the people performing the work, whether employees, contractors, or subcontractors. The enclosed Safety Advisory is being issued to reinforce regulatory requirements relating to ground disturbance activities near CER-regulated pipelines.

Safety Advisories are issued periodically to inform the oil and gas industry of an identified safety or environmental concern with the goal of preventing the occurrence of related incidents. A Safety Advisory serves to highlight CER requirements, and to convey the CER’s expectation that regulated companies take appropriate action to mitigate any potential impacts to people or the environment.

If you have any questions regarding this advisory, please contact the Director of Research and Innovation on our toll-free number at 1-800-899-1265 or via email to SafetyandInformationAdvisories@cer-rec.gc.ca.

Yours sincerely,

Signed by

Chris Loewen
Executive Vice President, Regulatory

Attachment

Safety Advisory
SA 2025-02
6 October 2025

SAFETY ADVISORY: Safety and Damage Prevention Practices related to Large Scale Projects Near Pipelines

Purpose of the Safety Advisory

The Canada Energy Regulator (CER) has conducted a focused review of multiple near-miss events reported during large scale, complex authorized third-party^Footnote 1 projects near CER-regulated pipelines. This analysis revealed recurring factors and potential process gaps that contributed to these events.

This Safety Advisory aims to share key findings and promote improved safety and damage prevention practices where large scale projects are occurring in the vicinity of pipelines. It outlines expectations and provides guidance to enhance communication and ensures that ground disturbance activities near CER-regulated pipelines are carried out safely.

This Safety Advisory is directed to:

• Project Managers for large or complex municipal, industrial, and commercial development projects near CER-regulated pipelines, (“Project Owners”);
• people performing the work, including contractors, subcontractors, and Project Owner’s employees (“Workers”); and
• CER-regulated pipeline companies (“Pipeline Companies”).

Background

Annual Review of Unauthorized Activity Reports

As part of its ongoing compliance and oversight efforts, the CER reviews approximately 350 reports of alleged unauthorized activities each year. These reports, submitted by regulated pipeline companies, document potential violations of the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations (DPR-A). Under the DPR-A, companies must report any unauthorized activity that could pose a risk to pipelines, even if no actual damage occurred. These events are classified as “near-misses” because they did not result in harm to people, regulated infrastructure, or the environment.

This advisory focuses on near-miss events that occurred during regulated company-approved, large-scale industrial, municipal, or residential development projects. These projects typically span several weeks or months and involve experienced project owners and contractors. Given the volume of such projects near pipelines across Canada, analyzing these events presents valuable opportunities to strengthen safety practices.

Examples of near-miss events analyzed for this advisory include:

• contractor installation of multiple steel piles on both sides of a CER-regulated pipeline, with the closest pile driven just 56 centimetres from the operating gas line during an industrial site expansion project;
• contractor grading directly above a pipeline, coming within 15 centimetres of its surface during site preparation for a commercial development; and
• contractor grading over a pipeline and installation of a fence within the strip of land measured 30 metres on each side from the centerline of a pipe (prescribed area) as part of a residential development project.

Common Contributing Factors Identified by the CER

Following its review, the CER identified several recurring issues that contributed to the events:

• Inadequate communication among parties involved.
• Failure to obtain approval from the pipeline company for changes or deviations from the original scope of work.
• Work conducted near the pipeline without a pipeline company representative present, in violation of the safety measures outlined in the written consent.
• Excavation outside the authorized work area described in the locate ticket or without written consent from the pipeline company.
• Digging under non-compliant conditions, including:
  • after the locate ticket had expired;
  • before receiving a locate response;and
  • misinterpreting or disregarding markings, flags, or stakes.
• Lack of awareness of site-specific safety protocols including pipeline markers and flags.
• Insufficient review or understanding of the requirements detailed in the written consent and locate ticket.
• Unauthorized operation or parking of heavy equipment over the pipeline.
• Inadequate on-site supervision and guidance for workers.

Responsibilities and Coordination for Safe Work Near CER-Regulated Pipelines

Any party conducting ground disturbance, construction, or operating vehicles or mobile equipment near a CER-regulated pipeline, including Project Owners and their Workers, must adhere to the requirements outlined in the DPR–A. The DPR-A outlines essential steps for anyone working in proximity to these pipelines to work safely and remain compliant with regulatory requirements.

Although they are typically professionally managed and executed, large-scale municipal, commercial, and industrial projects can be challenging to manage because they often extend over multiple days or months and involve numerous contractors and sub-contractors. As such, effective coordination and communication are critical to minimizing the risk of incidents. Communication is a shared responsibility, and all parties must actively contribute to maintaining safety throughout the project lifecycle.

By identifying common risks and issues in advance, pipeline companies, and those planning and conducting activities near pipelines can proactively address potential hazards. The CER has developed this guidance to support Pipeline Companies, Project Owners, and Workers in mitigating these risks and promoting safe practices.

For Project Owners with Projects Near CER-Regulated Pipelines

Project Owners are responsible for ensuring that any work planned near a pipeline complies with all applicable regulatory requirements, as well as any additional conditions imposed by the Pipeline Company. For large-scale projects, Project Owners typically coordinate ground disturbance activities and vehicle crossings, both of which require written consent from the Pipeline Company under sections 10 and 12 of the DPR–A. Additionally, ground disturbance activities require a locate request, as outlined in section 3 of the DPR–A.

To ensure compliance, mitigate safety risks, and avoid delays, Project Owners and Workers should clearly define who is responsible for obtaining the necessary locates and permissions and establish a process for managing, tracking, and communicating these requirements to the Workers. This helps ensure that no critical steps are overlooked.

Under section 4 of the DPR–A, Project Owners have a duty to inform their employees, contractors, and subcontractors of the specific rules and safety requirements applicable to the work. The following section provides guidance on how to fulfill this duty effectively. Pipeline Companies may also impose additional conditions, safety measures, or information that must be followed. This information is essential for fostering a shared understanding of the precautions required when working near pipelines.

For Workers (Project Owner’s employees, contractors, or sub-contractors)

Worker Responsibilities

Contractors, such as equipment operators, play a critical role in maintaining site safety and regulatory compliance during construction projects near CER-regulated pipelines. These individuals must be informed of, have access to, and understand the hazards, safety measures, and regulatory requirements associated with ground disturbance and the operation of vehicles or mobile equipment near pipelines.

It is equally important that Workers are aware of situations where a Pipeline Company representative must be present onsite, and that they always follow the representative’s instructions when working near the pipeline.

To support safe and compliant operations, the following checklist outlines key responsibilities and best practices for Workers:

For Pipeline Companies

Pipeline Companies’ Responsibilities in Managing Complex Projects Near Pipelines

Pipeline companies should account for the complexity of large-scale projects to ensure project owners have all necessary information to work safely near pipelines. Pipeline Company requirements are outlined in the Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies (DPR-O). In addition, the Canadian Energy Regulator Onshore Pipeline Regulations (OPR) requires regulated pipeline companies to be proactive to anticipate, prevent, manage, and mitigate damage to their pipelines.^Footnote 2 These obligations are not transferable to the Project Owner.

The OPR requires companies to maintain a management system that includes specific processes outlined in subsection 6.5(1). Pipeline companies should apply these existing processes to effectively manage the complexity of multi-day, multi-stakeholder projects.

From initial review through execution, pipeline companies should integrate management system processes into their oversight of complex third-party projects.

The following outlines key regulatory requirements and guidance on how to apply them in the context of complex project oversight.

Further Information

If you have any questions regarding this Safety Advisory please contact the Director, Research and Innovation on our toll-free number at 1-800-899-1265 or by email at SafetyandInformationAdvisories@cer-rec.gc.ca.

References

1. CER – Damage Prevention Pipeline Company Stakeholder Page (includes links to the OPR, DPR-A, and the DPR-O
2. CER – Damage Prevention Contractors Stakeholder Page
3. Guidance Notes – Canadian Energy Regulator Pipeline Damage Prevention Regulation
4. Canadian Energy Regulator Act
5. Canadian Energy Regulator Onshore Pipeline Regulations
6. CSA Z662:23 Oil and Gas Pipeline Systems

Date modified:

2025-10-06