HSG47, Avoiding danger from underground services, is aimed at everyone who plans, manages or carries out work on or near buried apparatus. The third edition still organises a safe system into three parts: plan the work, locate and identify buried services, then excavate safely. The official page is on the HSE website.
PAS 128 does not replace that guidance. It makes the middle step auditable. A quality-levelled drawing shows what was recorded, seen, detected or exposed. An incident investigation can read those labels. A coloured photocopy with no provenance cannot.
Confusion happens when teams treat a PAS 128 issue as permission to dig without further locating on the day. HSG47 still expects competent use of locating tools and a method that matches the residual risk. A QL-B line is a strong clue. It is not a surveyed invert you can scrape with a bucket.
Planning is the other join. Type D records searches are how you plan which owners to consult and which crossings are sensitive. Type B detection is how you locate. Type A is how you confirm the crossings that would hurt someone if they were wrong. That sequence is HSG47 in PAS clothing.
If you are writing a construction-phase plan, attach both documents: HSG47 for the safe system, and a named PAS 128:2022 quality-level mix for the information you will actually hold. Then commission the PAS 128 survey early enough that the drawing exists before the first excavation permit is printed.
HSG47 is guidance, not an Act, but it describes what the HSE considers good practice when someone is hurt. “We had a PDF of old plans” is a weak sentence in that conversation. “We held a quality-levelled Type B model and we still used locating tools on the day” is a stronger one.
The three parts of the safe system should appear in the construction-phase plan as named actions, not as a pasted paragraph. Who plans. Who locates. Who excavates. PAS 128 sits under the second name. If it sits under nobody, it will be treated as a consultant appendix and ignored.
Training still matters. A brilliant drawing in a cabin that nobody on the excavator has seen is decoration. Print the key. Mark the residual-risk crossings. Say which lines are assumed.
Do not use PAS 128 as a way to outsource HSG47. The specification does not operate the machine. It tells the person who does what the last surveyor believed about the ground.
Permit packs should include the quality-level key and the residual-risk crossings, not only a thumbnail of the whole site. People in a trench read the crossing in front of them.
If a strike still happens, the questions will be simple: what did you plan, what did you locate, how did you excavate? Have a sentence for each. PAS 128 is the middle sentence. It is not all three.
Refresh the drawing when the design moves. An HSG47 plan that points at last quarter’s model is a plan that points at a different site.
Read the official HSE page for HSG47 and the CICES notes for PAS 128. They are written for different jobs. Forcing them into one sentence is how teams either over-claim the drawing or under-plan the excavation. Keep both documents. Keep both duties.
Take this into the brief
If you only read one official page this month, read HSG47 on the HSE site and then write three named owners on your project: who plans, who locates, who excavates. PAS 128 sits under the second name. When those names are missing, the drawing becomes an appendix and the safe system becomes a poster.
Alignment is a habit, not a logo. Refresh the model when the design moves. Print the quality-level key on the sheet that will hang in the cabin. Keep locating tools on the excavator even after a beautiful Type B issue. That is what “HSG47 and PAS 128 together” means in a UK trench, rather than in a marketing sentence.