A sign-in sheet proves people were in a room. It does not prove an oilfield crew recognized the alarm, chose the upwind route, accounted for a vacuum-truck driver, or fixed the windsock no one could see from the transfer area.
Most OSHA 1910.38 drill-record advice stops at general requirements that could apply to an office or warehouse. A Permian contractor needs those requirements translated into shift changes, third-party crews, H2S alarms, blocked access roads, workover rigs, tank batteries, and operator document requests.
Start with applicability. Section 1910.38 does not independently require every employer to create an emergency action plan. It governs an EAP when another standard in OSHA Part 1910 requires one. Section 1910.39 uses the same conditional structure for fire prevention plans. When those sections apply, OSHA 1910.38 does not prescribe a universal emergency-drill frequency or a ten-field drill log. It requires the plan, alarm, training, and review framework. OSHA's evacuation guidance then recommends practice drills and a post-drill evaluation. A drill record shows how that framework worked in the field without presenting recommended fields as regulatory requirements.
Start with the text
Requirements and limits under 1910.38 and 1910.39
Label the source of each obligation: regulation, OSHA guidance, operator requirement, or company safety standard. All four can control the job, but they are not interchangeable.
Required when 1910.38 applies
Plan elements, a compliant alarm system, trained evacuation assistants, and plan review with covered employees when the plan is developed or assigned, responsibilities change, or the plan changes.
Required when 1910.39 applies
Fire-hazard and ignition-control content, combustible-waste controls, maintenance safeguards, responsible job titles, and employee information about relevant fire hazards.
Recommended by OSHA guidance
Practice drills often enough to keep employees prepared, followed by a management-and-employee debrief that identifies strengths, weaknesses, and improvements.
Strong documentation practice
A versioned drill log with participants, response benchmarks, observations, deficiencies, corrective-action ownership, and verified closure.
The common overstatement
Do not write “OSHA requires quarterly emergency drills” or “1910.38 requires these ten drill-log fields” unless another applicable rule creates that obligation. The regulation requires EAP elements, alarms, trained evacuation assistants, and employee review. OSHA's EAP guidance recommends drills as often as necessary and a post-drill evaluation.
29 CFR 1910.38
Emergency action plan
29 CFR 1910.39
Fire prevention plan
- Reporting fires and other emergencies
- Evacuation types and exit-route assignments
- Critical operations before evacuation
- Accounting for employees after evacuation
- Rescue and medical duties
- Plan contacts, alarm system, training, and review
- Major fire hazards and hazardous-material handling
- Ignition sources and necessary fire protection
- Flammable and combustible waste control
- Maintenance of heat-producing safeguards
- Responsible job titles for ignition and fuel hazards
- Employee information about fire hazards
Source: OSHA 1910.39
Make the plan site-specific
Five oilfield drill types worth documenting
1910.38 tells you what an EAP must address. The hazards, operating procedures, client rules, and other applicable standards determine which scenarios your crew should practice.
H2S alarm and muster
Scenario: Simulated fixed-monitor alarm during shift change; crew moves crosswind or upwind to the designated muster point.
Record: Alarm recognition, wind check, route used, headcount, escape-pack readiness, response time, and missed steps.
Connect to the site H2S contingency plan and operator requirements.
Fire and evacuation
Scenario: Simulated ignition near the engine or fuel-transfer area with one normal route blocked.
Record: Emergency report, distinctive alarm, alternate route, employee accounting, shutdown roles, and fire-equipment observations.
Connect directly to the EAP and, where applicable, the fire prevention plan.
Kick, blowout, or well-control response
Scenario: Simulated pit gain, gas-cut returns, or unexpected pressure requiring assigned well-control actions.
Record: Detection, communications, role execution, shutdown sequence, remote-control access, and escalation decision.
Use the applicable well-control program, operator rules, and drilling/workover procedures. Do not rely on 1910.38 alone.
Severe weather or shelter
Scenario: Lightning, tornado warning, high wind, flash flood, or dust event affecting the pad and access road.
Record: Warning source, stop-work decision, accountability, shelter or evacuation route, vehicle movement, and all-clear authority.
Tie the scenario to hazards the site can reasonably expect.
Medical or rescue coordination
Scenario: Simulated incapacitated worker with a restricted access point and delayed outside response.
Record: Who calls, who renders aid, who controls the scene, location directions, rescue limits, and handoff time.
Do not let a drill encourage untrained entry into an IDLH atmosphere.
OSHA includes 1910.38 among the standards relevant to oil and gas well drilling, servicing, and storage-tank work. Its oil and gas standards page is a useful starting point, but it does not replace the applicability review for a specific operation.
Build useful evidence
What a useful oilfield drill record should show
These fields are a practical recordkeeping framework, not a claim that 1910.38 lists a required form. Each field should help answer one question: did the crew execute the plan, and did the company correct what failed?
1. Identify the operation
- Company, operator/client, rig or facility, well/API number, county, and exact work area
- Date, local time, shift, weather, wind direction, and drill conductor
- Drill type and whether it was announced, unannounced, tabletop, or full movement
2. Tie it to the plan
- Scenario, initiating condition, and alarm signal used
- EAP, H2S contingency plan, or well-control procedure title and revision
- Expected actions, route, muster point, shutdown roles, and outside contacts
3. Record who did what
- Participant names, employer, crew role, and assigned emergency role
- Visitors or third-party personnel included in the headcount
- Observers, evaluators, and anyone absent who needs make-up review
4. Measure response
- Alarm recognition, movement start, last person at muster, and final headcount time
- Emergency notification or shutdown benchmark when the scenario includes it
- Use consistent start and stop points so results can be compared across drills
5. Capture performance
- What worked, what failed, and the exact location or role involved
- Alarm audibility, windsock visibility, route condition, PPE or escape-pack access, and roster accuracy
- Avoid vague notes such as “crew needs improvement” without a specific observed behavior
6. Close the loop
- Corrective action, priority, owner, due date, and status
- How closure will be verified: photo, work order, plan revision, training acknowledgment, or repeat drill
- Reviewer approval, closure date, and evidence beyond a blank signature line
Free field tool
Turn the checklist into a completed H2S drill record.
Record the site, participants, response time, equipment checks, deficiencies, corrective actions, and supervisor sign-off, then generate a downloadable PDF.
Filled example
Shift-change H2S alarm drill on a workover rig
This fictional example shows the level of specificity that turns a drill form into a useful training and audit record. It is not a substitute for your operator-approved plan.
Sample completed record
H2S alarm, alternate muster, third-party headcount
- Operation
- Mesa Well Service (fictional) · Workover Rig 12 · Martin County, Texas
- Drill date / shift
- July 17, 2026 · 05:55 CDT · night-to-day shift handover
- Scenario
- Simulated fixed H2S monitor alarm at the cellar during shift change; primary north muster point treated as downwind
- Plan in effect
- Site H2S Contingency Plan H2S-12, Rev. 4 · EAP EAP-WS-03, Rev. 7
- Alarm / initiation
- Drill conductor activated the designated simulated H2S alarm after confirming no actual gas reading
- Expected response
- Stop work, check wind, move crosswind then upwind to south muster, account for all personnel, report one missing visitor
- Participants
- 11 contractor employees, 2 operator representatives, 1 vacuum-truck driver · 14 people expected
- Timed results
- Movement began 00:18 · last person at muster 02:41 · correct headcount confirmed 03:12
- What worked
- Crew selected the alternate upwind muster point; driller brought the shift roster; all work stopped without re-entry
- Deficiency 1
- Vacuum-truck driver was absent from the paper roster; headcount was delayed 31 seconds
- Corrective action 1
- Rig manager to add third-party check-in board at doghouse entrance by July 18; verify with photo and next shift roster
- Deficiency 2
- South windsock was visible from the rig floor but not from the fluid-transfer area
- Corrective action 2
- Operator representative to install a second indicator at the transfer area by July 22; verify in pre-job walk
- Plan / training follow-up
- Revise visitor-accounting step in H2S-12; brief both crews and capture acknowledgments before next tour
- Review
- Drill led by Elena Ruiz, HSE Coordinator · reviewed by Rig Manager · follow-up check scheduled July 24
Why this record is stronger than “drill completed”
It ties performance to a specific plan revision, includes every employer on location, defines the timing benchmark, names the exact failure, assigns an owner and due date, and states how closure will be verified. A signature confirms review; it does not replace those facts.
Texas onshore operations
Texas RRC Rule 36 and the quarterly-drill myth
Texas Statewide Rule 36 is an important H2S overlay. Cite it accurately.
Rule 36 does require
- H2S safety training for employees working in covered areas when operations contain more than 100 ppm H2S
- Service-company certification that assigned personnel have the required training
- Training on H2S hazards, precautions, and safety or life-support equipment
- Additional supervisor knowledge, including shutdown, well-control, and contingency-plan duties
- Contingency planning and additional safeguards when the rule's exposure triggers apply
Rule 36 does not state
- A quarterly H2S drill frequency
- A required ten-field H2S drill form
- A three-year H2S drill-log retention period
- That every Rule 36 provision applies to every site without regard to concentration and exposure triggers
Read the current rule and applicability thresholds on the Railroad Commission's Statewide Rule 36 page. For a broader field checklist, use BasinCheck's Texas oilfield OSHA compliance resources.
One source of the frequency confusion is federal offshore rule 30 CFR 250.490(h) requires covered offshore facilities to conduct H2S drills for each person at least once every seven-day period and to keep attendance records for specified periods. That is not a quarterly Texas onshore Rule 36 requirement.
Your operator contract or company plan can still require quarterly drills. If it does, the drill log should say “company policy” or identify the contract section instead of attributing the schedule to Rule 36.
Revenue protection
Drill logs are evidence that the written program reached the field
The policy sets the expected response. The drill log shows whether the crew followed it and whether management fixed the gaps. That is why the record matters beyond an OSHA inspection.
Named participants connect the program to the crew assigned to the work.
A plan revision proves the crew practiced the current procedure.
Measured headcount and response benchmarks show performance, not attendance alone.
Closed corrective actions show management follow-through.
Operator and prequalification requests vary. Do not promise that a drill log alone will satisfy Chevron, ConocoPhillips, ISNetworld, Avetta, or Veriforce. Treat it as one record in the documentation stack: written programs, training evidence, JSAs, permits, inspection findings, incident records, and corrective-action closure.
See the full breakdown of safety records oil and gas operators request and use the free contractor prequalification toolkit to identify the rest of the package.
Keep the categories separate
How long to keep drill records
Sections 1910.38 and 1910.39 set no retention period for drill logs. Use the rule, contract, and record category that applies to the operation.
| Record | What the cited rule says | Practical action |
|---|---|---|
| 1910.38 / 1910.39 drill log | No drill-log retention period is stated in these two sections. | Set a written company rule that covers plan revisions, contract needs, investigations, and legal advice. |
| Texas Rule 36 H2S drill log | Rule 36 does not create a quarterly drill-log mandate or a drill-log retention period. | Retain records required by your operator, contract, plan, or other applicable standard; keep Rule 36 training evidence available as required. |
| Federal offshore H2S drill attendance | 30 CFR 250.490(h) has its own frequency and attendance-retention rules for covered offshore facilities. | Apply only when that offshore rule governs the operation; do not use it as a Texas onshore Rule 36 citation. |
| OSHA 300, 300A, and 301 | Five years following the end of the calendar year covered under 29 CFR 1904.33. | Keep this separate from drill records. The five-year rule does not become a drill-log rule. |
| Operator / prequalification evidence | The requested lookback depends on the client, portal, work scope, and contract. | Check the current questionnaire and contract before assigning a universal retention period. |
A clean internal policy
Name the record category, governing source, retention trigger, period, owner, storage location, and legal-hold exception. Then apply the policy consistently. If a client requires a longer period, keep the longer period and record the contractual source.
Use the record on the next tour
For the next tour, choose one realistic scenario and close every action it produces.
- 1Select one scenario from the current site plan and define the expected actions.
- 2Use a current roster that includes operator representatives, vendors, and visitors.
- 3Time only benchmarks with clear start and stop points.
- 4Write observations as facts: person, place, equipment, action, and result.
- 5Assign every deficiency to one owner with a due date and closure method.
- 6Update the plan or employee review record if the drill exposes a procedural change.
OSHA 1910.38 drill record FAQ
Direct answers for oilfield safety managers building emergency-drill records.
Free field tool
Turn the checklist into a completed H2S drill record.
Record the site, participants, response time, equipment checks, deficiencies, corrective actions, and supervisor sign-off, then generate a downloadable PDF.
Continue the compliance check
H2S documentation guide
Training, monitoring, wind, muster, and field-record details.
OSHA penalty estimator
Model current penalty exposure for potential citation categories.
H2S radius of exposure calculator
Estimate Texas Rule 36 radii for initial planning.
Audit-ready contractor records
Build the wider evidence package around the drill record.