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What is the difference between ongoing and completed operations additional insured?

Updated . Sources for every claim are listed at the end.

Short answer

Ongoing operations additional insured coverage protects the operator for injury or damage that happens while your work is underway. Completed operations coverage protects the operator for injury or damage caused by your work after it is finished, such as a connection you made that fails months later. On standard ISO forms they are separate endorsements: CG 20 10 or CG 20 38 for ongoing, CG 20 37 for completed.

  • The ongoing forms expressly exclude injury or damage after your work is completed, so an ongoing-only endorsement leaves the operator uncovered for the claims that often show up last.
  • Operators commonly ask for both. Check that your policy has both, and that the completed operations piece lasts as long as the MSA requires.
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Ongoing operations: while you are on location

ISO form CG 20 10 adds the scheduled party as an additional insured for injury or damage "caused, in whole or in part, by" your acts or omissions, or those acting on your behalf, "in the performance of your ongoing operations for the additional insured(s)." CG 20 38 does the same thing on a blanket basis for anyone you agreed in writing to add.

Both forms then exclude bodily injury or property damage occurring after:

  • all work on the project (other than service, maintenance or repairs) has been completed, or
  • the part of your work that caused the injury "has been put to its intended use" by anyone other than another contractor working on the same project.

CG 20 38 also says plainly that a party's status as an additional insured "ends when your operations for the person or organization... are completed."

MSA clause to endorsement

Which endorsement satisfies which MSA clauseAdditional insured: CG 20 10 and CG 20 37 on general liability, CA 20 48 on auto. Primary and non-contributory: CG 20 01. Waiver of subrogation: CG 24 04, CA 04 44, and the Texas workers comp waiver. Contractual liability supports indemnity. Pollution: contractors pollution liability and CA 99 48 for hauling. Notice of cancellation needs an endorsement.What the MSA saysWhat has to be on your policy"Name Company Group asadditional insured"GL: CG 20 10 + CG 20 37 (or blanket AI)Auto: CA 20 48 · Umbrella: follow form"Contractor's insurance is primaryand non-contributory"GL: CG 20 01 primary andnoncontributory, carried to the umbrella"Contractor waives all rightsof subrogation"GL: CG 24 04 · Auto: CA 04 44WC: Texas waiver of subrogation endorsement"Insurance shall supportContractor's indemnity obligations"GL contractual liability ("insured contract")Watch for CG 21 39, which strips it out"Contractor shall carrypollution liability"Contractors pollution or GL buybackHauling: auto pollution, CA 99 48"30 days written noticeof cancellation"A notice-to-third-parties endorsementon the policy (a certificate cannot do it)
Standard ISO form numbers shown; many energy policies use the insurer's own versions with the same effect. What matters is that the wording on your policy matches the wording in the exhibit, and that you can produce the endorsement when a reviewer asks for it.

Completed operations: after you leave

CG 20 37 covers the additional insured for injury or damage "caused, in whole or in part, by 'your work'" performed for that party and "included in the 'products-completed operations hazard.'"

The standard GL form (CG 00 01) defines when work is completed. Work is deemed completed at the earliest of: when all the work called for in your contract is done; when all work at one job site is done, if the contract covers several sites; or when that part of the work has been put to its intended use by someone other than another contractor on the same project. Work that may still need service, maintenance, correction or repair "but which is otherwise complete, will be treated as completed."

For oilfield crews, that line comes quickly. A flowline tie-in, a wellhead repair or a tank battery hookup is "completed" once it is put to use. A failure the next week is a completed operations claim.

Side by side

Here is how the three standard forms divide the job.

ISO additional insured forms for ongoing and completed operations
FormWho is addedWhen it applies
CG 20 10Parties named in the scheduleDuring your ongoing operations; excludes injury after work is completed or put to use
CG 20 38Anyone you agreed in writing to add, plus others that contract requiresDuring ongoing operations; status ends when your operations for them are completed
CG 20 37Parties named in the scheduleInjury or damage from your completed work within the products-completed operations hazard

What both kinds share: limits tied to the contract

All three 12 19 edition forms carry the same two limits:

  • The coverage applies "only... to the extent permitted by law," and if a contract requires it, it "will not be broader than that which you are required by the contract or agreement to provide."
  • If a contract requires the coverage, the most the insurer pays for the additional insured is the lesser of the amount the contract requires or the limits available on your policy.

So if your MSA only asks for ongoing operations coverage, or asks for lower limits than you carry, the additional insured protection can shrink to match. In Texas, that interaction also runs through the anti-indemnity act, which is why the indemnity and insurance sections should be read together. See indemnity vs additional insured.

What to check on your policy

  • Is there a completed operations endorsement at all? If your certificate shows a blanket additional insured endorsement, find the form number and confirm it reaches completed operations. CG 20 38, the standard ISO blanket form, is ongoing only.
  • How long does the MSA want completed operations to last? If the MSA requires completed operations coverage to continue after the work ends, that is a renewal issue as much as an endorsement issue.
  • Is the products-completed operations aggregate adequate? On the standard form it is a separate aggregate limit.
  • Does the umbrella follow? If the MSA requires additional insured status on the umbrella, confirm the umbrella recognizes both. See blanket additional insured endorsements.

Common questions

Does CG 20 38 cover completed operations?

No. CG 20 38 12 19 says additional insured status ends when your operations for that party are completed, and it excludes injury after the work is completed or put to its intended use. Completed operations needs a separate form such as CG 20 37.

When is oilfield work "completed" under the GL policy?

Under the CG 00 01 definition, at the earliest of: all contract work done, all work at that site done, or that part of the work put to its intended use by someone other than another contractor on the same project.

Do these forms cover the operator’s own negligence?

The ISO forms cover injury or damage caused in whole or in part by you or those acting for you. An injury caused only by the operator generally falls outside that wording. Carrier forms vary.

Is a scheduled endorsement better than blanket?

Neither is better on its own. Scheduled forms need a policy change for each new operator; blanket forms depend on a signed written contract. The bigger question is whether both ongoing and completed operations are covered.

Sources

  1. ISO CG 20 10 12 19, Additional Insured: Scheduled Person or Organization (copy published by New York OGS). Ongoing operations wording, completed work exclusions, contract and law limits, lesser-of limits.
  2. ISO CG 20 38 12 19, Additional Insured: Automatic Status When Required in Written Construction Agreement (copy published by IIAT). Blanket ongoing operations wording; status ends when operations are completed.
  3. ISO CG 20 37 12 19, Additional Insured: Completed Operations (copy published by IIAT). Completed operations wording tied to the products-completed operations hazard.
  4. ISO CG 00 01 04 13, Commercial General Liability Coverage Form (sample copy published by Sonoma County). Definition of products-completed operations hazard and when work is deemed completed.

This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.

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