H2S Documentation Guide
Hydrogen sulfide (H2S) documentation is among the most scrutinized records during oilfield contractor audits. Texas Railroad Commission Rule 36, operator requirements, and OSHA 1910.134 all demand specific records: calibration certificates with gas concentration and expiration dates, daily bump test logs, wind direction and muster point documentation, training expiration tracking, and complete emergency drill records. This guide shows you exactly what separates audit-failing documentation from audit-ready records, with side-by-side comparisons and checklists you can implement today.
Bad Log vs. Audit-Ready Log
The difference between passing and failing an H2S documentation audit often comes down to specificity. Here's what auditors look for:
Will fail operator audit
Date: 1/15/25
Location: Site A
Calibration: ✓ Done
Wind: Light
Muster: Parking lot
Participants: Crew
Drill Time: ~5 min
- ❌ Generic location (which Site A?)
- ❌ No calibration details or certificate
- ❌ Wind direction not specified
- ❌ Muster point not GPS-specific
- ❌ No participant names
- ❌ Approximate drill time
Passes all requirements
Date: 2025-01-15 0630
Location: API #42-103-12345
Calibration: BW GasAlert #SN-4521, 25ppm H2S gas (exp: 03/2025), Cal date: 01/01/25
Wind: NNW 8mph @ 0630
Muster: 31.456°N, 102.789°W (200m SE)
Participants: J. Smith, R. Jones, M. Davis (signatures attached)
Drill Time: 4:32 (alarm-to-headcount)
- ✓ Well API# for exact location
- ✓ Detector S/N, gas conc., expiration
- ✓ Wind direction + speed + time
- ✓ GPS coordinates for muster
- ✓ All participant names
- ✓ Precise drill time
Calibration vs. Bump Test Requirements
These are different tests with different purposes. Auditors check for both.
Functional verification before each use
A bump test verifies the detector responds to gas but doesn't verify accuracy. Quick (<1 min) check that sensors are functional.
Document:
- • Date and time
- • Detector ID/serial number
- • Pass/Fail result
- • Tester name
- • Action if failed (remove from service)
Accuracy verification with certified gas
Calibration adjusts detector readings to match known gas concentrations. Ensures accuracy of readings. Requires certified calibration gas.
Document:
- • Detector model and serial number
- • Calibration gas concentration (ppm)
- • Calibration gas lot # and expiration
- • Pre-calibration readings
- • Post-calibration readings
- • Technician name and certification
Common Audit Finding
"Calibration checkbox marked but no supporting certificate or calibration gas details recorded." Checking a box isn't documentation. Auditors want to see the gas concentration, lot number, and expiration date.
Wind Direction & Muster Point Documentation
Wind direction determines evacuation routes. Document it properly or your H2S contingency plan is incomplete.
Required Wind Documentation Fields
Direction
Compass direction (N, NNE, NE, etc.) wind is coming FROM
Speed
Wind speed in mph. Variable winds require more frequent checks.
Time of Reading
When the wind reading was taken. Recheck if conditions change.
Resulting Muster Point
GPS coordinates or clear landmark UPWIND of operations.
Good Muster Point Documentation
- ✓ GPS coordinates (31.456°N, 102.789°W)
- ✓ Distance and direction from wellhead
- ✓ Photo of location with windsock visible
- ✓ Updated when wind shifts >45°
Bad Muster Point Documentation
- ✗ "The parking lot" (which parking lot?)
- ✗ "By the gate" (no GPS or distance)
- ✗ Same muster point regardless of wind
- ✗ No photo or visual reference
H2S Training Expiration Management
Training gaps are the most common H2S documentation failure. Here's how to track certifications properly.
Training Matrix Requirements
| Employee | Course Type | Completed | Expires | Status |
|---|---|---|---|---|
| John Smith | H2S Awareness (IADC) | 2024-03-15 | 2026-03-15 | Current |
| Mike Davis | H2S Awareness (SafeLand) | 2023-02-01 | 2025-02-01 | Expiring |
| Robert Jones | H2S Awareness | 2022-06-10 | 2024-06-10 | Expired |
Days Before
Start renewal process 60 days before expiration
Days Warning
Automated alerts at 30 days remaining
Days Grace
No grace period. Expired means off H2S sites
Texas RRC Rule 36 Requirements
Texas Railroad Commission Statewide Rule 36 sets minimum H2S safety requirements for operations in Texas. Here's what you need.
- Written H2S contingency plan (site-specific)
- Current training records for all personnel
- Emergency drill records (annual minimum)
- Equipment calibration/testing logs
- Wind direction monitoring records
- Public notification documentation (if applicable)
Rule 36 requirements escalate based on radius of exposure (calculated from well potential H2S concentration and flow rate):
- 100 ft radius:Basic contingency plan required
- 500 ft radius:Briefing of public officials required
- 3,000 ft radius:Public notification required
Frequently Asked Questions
Digitize Your H2S Documentation
BasinCheck captures all required H2S documentation fields with GPS coordinates, automatic timestamps, and photo attachments. Training expiration alerts ensure you never have a gap.