Oil and gas safety moment for well site crews

The rule

What OSHA requires

Plain-language summary. Each line links to the exact paragraph of the regulation.

• OSHA's hazard communication standard applies to any chemical known to be present in the workplace in a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.

  “This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.”

  29 CFR 1910.1200(b)(2)

• Employers must develop, implement and maintain a written hazard communication program at each workplace. It must include a list of the hazardous chemicals known to be present and the methods used to tell employees about the hazards of non-routine tasks and of chemicals in unlabeled pipes in their work areas.

  “Employers shall develop, implement, and maintain at each workplace, a written hazard communication program”

  29 CFR 1910.1200(e)(1)

• Where an employer's hazardous chemicals could expose another employer's employees, such as contractors on site, the written program must also include how the other employers will get access to safety data sheets and be told about precautionary measures and the labeling system used.

  “Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed”

  29 CFR 1910.1200(e)(2)

• With limited exceptions, each container of hazardous chemicals in the workplace must be labeled, tagged or marked with either the product identifier, signal word, hazard statements, pictograms and precautionary statements required on shipped container labels, or the product identifier plus words, pictures or symbols that give at least general information about the chemical's hazards.

  “the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either”

  29 CFR 1910.1200(f)(6)

• The employer must keep copies of the safety data sheet for each hazardous chemical in the workplace and make sure they are readily accessible to employees in their work areas during each work shift. Electronic access is allowed if it creates no barriers to immediate employee access.

  “readily accessible during each work shift to employees when they are in their work area(s)”

  29 CFR 1910.1200(g)(8)

• Where employees travel between workplaces during a work shift, the safety data sheets may be kept at the primary workplace facility, but the employer must make sure employees can immediately obtain the required information in an emergency.

  “the employer shall ensure that employees can immediately obtain the required information in an emergency.”

  29 CFR 1910.1200(g)(9)

• Employers must provide effective information and training on hazardous chemicals in the work area at the time of initial assignment, and whenever a new chemical hazard the employees have not been trained about is introduced.

  “Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment”

  29 CFR 1910.1200(h)(1)

• Training must include the methods and observations that can be used to detect the presence or release of a hazardous chemical in the work area, such as employer monitoring, continuous monitoring devices, and the look or odor of a chemical being released.

  “Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area”

  29 CFR 1910.1200(h)(3)(i)

• OSHA's process safety management (PSM) standard does not apply to oil or gas well drilling or servicing operations. It also does not apply to retail facilities or to normally unoccupied remote facilities (29 CFR 1910.119(a)(2)).

  “Oil or gas well drilling or servicing operations”

  29 CFR 1910.119(a)(2)(ii)

• Where PSM does cover a process, each employee operating it, and each employee before operating a newly assigned process, must be trained in an overview of the process and its operating procedures. The training must emphasize the specific safety and health hazards, emergency operations including shutdown, and safe work practices for the employee's job tasks.

  “The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.”

  29 CFR 1910.119(g)(1)(i)

Who must be trained

Employees must get effective information and training on the hazardous chemicals in their work area at the time of their initial assignment (29 CFR 1910.1200(h)(1)). Where OSHA's process safety management standard covers a process, each employee operating it, and each employee before operating a newly assigned process, must be trained in an overview of the process and its operating procedures (29 CFR 1910.119(g)(1)(i)). That standard does not apply to oil or gas well drilling or servicing operations (29 CFR 1910.119(a)(2)(ii)).

When to retrain

Employers must provide hazard communication information and training again whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area (29 CFR 1910.1200(h)(1)). Under the current version of the rule, which took effect July 19, 2024, employers must also, as necessary, provide any additional training for newly identified hazards no later than November 20, 2026 for substances and May 19, 2028 for mixtures (29 CFR 1910.1200(j)(1), (j)(2)(ii) and (j)(3)(ii)). Where PSM covers a process, refresher training must be provided at least every three years, and more often if necessary (29 CFR 1910.119(g)(2)).