H2S Answers vs. Interpretation

1. Common H2S Training
Questions
(April 1, 2018)
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2. 2
Q: Are there Federal and State regulatory requirements that detail H2S training requirements for land
based E&P operations in Texas, Oklahoma, New Mexico and Arkansas?
A: Yes
FEDERAL
OSHA
29 CFR 1910.1200
Under OSHA’s Hazard Communication standard if an employer determines that employees may be
exposed to a hazardous chemical (H2S) during normal operations or in a foreseeable emergency then
they are required to train employees in (refer 29 CFR 1910.1200 (h)(3)):
 Methods and observations that may be used to detect the presence or release of a hazardous
chemical in the work area.
 The hazards (physical, health, simple asphyxiation, combustible dust, and pyrophoric gas
hazards, as well as hazards not otherwise classified) of the chemicals in the work area.
 The measures employees can take to protect themselves including specific procedures the
employer has implemented to protect employees from exposure to hazardous chemicals, such
as appropriate work practices, emergency procedures, and personal protective equipment to be
used.
 The details of the hazard communication program developed by the employer, including an
explanation of the labels received on shipped containers and the workplace labeling system
used by their employer; the safety data sheet, including the order of information and how
employees can obtain and use the appropriate hazard information.
STATE
Texas RailRoadCommission
Rule 36 Section (c)(13)
The intent in this provision is to insure that the personnel are trained to prevent and react to an
emergency to the degree that safety will be ensured.
Section (c)(13)(A) states that "Each operator whose operations contain H2S in excess of 100 parts per
million shall train its employees working in the affected area.
Section (c)(13)(B) requires that service company personnel also be trained if the work they are
performing at well sites, gasoline plants or pipelines could allow the escape of H2S gas. This provision,
therefore would not apply to personnel delivering equipment, painting tanks, hauling pipe, etc.
Section (c)(13)(C) states "The training of personnel shall include the following elements":
iii.
i. Hazards and Characteristics of Hydrogen Sulfide. - In training personnel, it is suggested that
each individual be instructed as to the toxic effects of Hydrogen Sulfide and the physical effects
at various levels of Hydrogen Sulfide exposure.
ii. Safety Precautions - Safety precautions normally vary depending on the nature of the situation.
The surrounding working conditions and environment would dictate what specific precaution
should be observed. In general, when working in a Hydrogen Sulfide environment, individuals
should be aware of the Hydrogen Sulfide concentration present, they should not work alone in
contaminated areas (make use of the "buddy system") and they should be observant of the
wind direction at all times.
Operation of safety equipment and life-support system. - All personnel should be able to
operate safety and life-support systems, including fresh-air breathing equipment and
resuscitation equipment. Routine drills on the use of this equipment should be conducted at
frequent intervals.

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Section (c)(13)(D) specifies that supervisory personnel shall be additionally trained in the following:
iii.
i. Effect of Hydrogen Sulfide on metal components in the system.
ii. Corrective action and shut-down procedures, and when drilling a well, blowout prevention and
well control procedures.
Full knowledge of the requirement of the contingency plan, when such plan is required. For this
section, supervisory personnel would be the persons in charge of the operation at a particular
time. Such a person must be on site at all times if the operation has a public area in the 100
parts per million radius of exposure or if the radius of exposure is greater than 3,000 feet.
Oklahoma Corporation Commission
Title 165 Chapter 10
(f)Training and requirement provision. Each operator shall provide appropriate H2S training for its
employees who will be onsite. This training should include:
1) Hazards and characteristics of hydrogen sulfide.
2) Effect on metal components of the system.
3) Operations of safety equipment and life support systems.
4) First aid in event of an employee exposure.
5) Use and operation of H2S monitoring equipment.
6) Emergency response procedures to include corrective actions, shut-down procedures,
evacuation routes, and rescue methods.
New Mexico
Title 19 Chap. 15
19.15.11.9 A. Training and drills. When required. If a well, facility or operation involves a potentially
hazardous volume of hydrogen sulfide, the person shall develop a hydrogen sulfide contingency plan
that the person will use to alert and protect the public in accordance with the Subsections B through I
of 19.15.11.9 NMAC.
19.15.11.9 B (d) Training and drills. The hydrogen sulfide contingency plan shall provide for training and
drills, including training in the responsibilities and duties of essential personnel and periodic on-site or
classroom drills or exercises that simulate a release, and shall describe how the person will document
the training, drills and attendance.
19.15.11.13 Personal Protection and Training: The person shall provide persons responsible for
implementing a hydrogen sulfide contingency plan training in hydrogen sulfide hazards, detection,
personal protection and contingency procedures.
Arkansas Oil and Gas Commission
Rule B-41
VII. TRAINING PROVISION
Each operator and contractor shall provide appropriate Hydrogen Sulfide H2S training for its employees
who will be on-site. All personnel must have in their possession, current proof of annual training. This
training should include the following:
1. Hazards and characteristics of Hydrogen Sulfide H2S.
2. Operations of safety equipment and life support systems.
3. First aid in the event of an employeeexposure.
4. Use and operation of Hydrogen Sulfide H2S monitoring equipment.
5. Emergency response procedures to include corrective actions, shutdown procedures,
evacuation routes and rescue methods.

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Q: Do federal or state regulations prescribe how many hours H2S training must last?
A: No, there are no time requirements that must be met for regulatory compliance.
Q: Does API RP 49 (Recommended Practice for Drilling and Well Servicing Operations Involving
Hydrogen Sulfide) prescribe how many hours H2S training must last?
A: No. However, API RP 49 does establish minimum H2S training content including specialized training
for supervisory personnel, visitors, and other non-regularly assigned personnel.
Q: Is the ANSI/ASSE Z390.1-2017 required to be followed by a federal or state regulatory agencies?
A: No. The ANSI/ASSE Z390.1-2017 is not a regulatory requirement. Instead, it is considered a
recommended practice that is voluntary.
Q: According to the ANSI/ASSE Z390.1-2017 how many hours should H2S training last?
A: ANSI/ASSE Z390.1-2017, Section 3.1 recommends (does not mandate) a minimum training time of 3-4
hours.
Q: How many hours should H2S training be?
A: H2S training time should be based on a training needs assessment not on a specific period of time.
The 3-4 hours recommended in the ANSI/ASSE Z390.1-2017 may be sufficient for some employees.
However, after doing a training needs assessment you may find that there are those situations where 3-
4 hours may be inadequately short (i.e. individuals who actively work in environments above the
occupational exposure limit), or where the recommended time may be too long (i.e. individuals going
through annual refresher training). Therefore, what employers should focus on is not teaching to time
but teaching content for learner comprehension and retention.