Preserve the Well, Pressure, and Exposure Context
Classify Events by Their Potential Consequences
Relevant categories include:
- Loss of containment from pressurized equipment
- Unexpected pressure or flow
- Well-control events and related near misses
- Dropped objects and suspended-load incidents
- Tubular-handling injuries
- Caught-between and machinery-contact events
- Hydrogen sulfide alarms and suspected exposures
- Hydrocarbon vapor exposure
- Oxygen-deficiency concerns
- Silica exposure during completion activities
- Fires and ignition events
- Falls from rigs, tanks, or platforms
- Vehicle collisions and equipment interactions
- Heat illness, fatigue-related concerns, and manual-handling injuries
Record high-potential events even when no injury occurs. Actual outcome and potential severity should remain separately identifiable.
Capture the Conditions at the Time
Include:
- Asset, field, pad, and well identifier
- Drilling, completion, servicing, flowback, or production phase
- Task and job step
- Well and equipment status
- Relevant pressure and temperature information
- Fluid or gas characteristics, where known
- Equipment, line, valve, or connection involved
- Isolation and depressurization status
- Personnel location relative to the hazard
- Simultaneous activities
- Gas readings and instrument details
- Weather and wind conditions
- Immediate actions and restrictions
- Photographs, witness accounts, and technical records
Preserve the source and timing of operational readings. Information taken after shutdown may not describe the conditions immediately before the event.
Investigate Equipment, Procedures, and Work Coordination
Event → Operating-State Review → Equipment Assessment → Personnel Exposure Review → Contributing Causes → Corrective Work → Verification
Questions may include:
- Did the actual configuration match the job plan?
- Was pressure verified before opening the equipment?
- Were all relevant energy sources identified?
- Did personnel enter an area exposed to a potential release?
- Was inspection evidence available for the component involved?
- Did an adjacent activity change the risk?
- Was the gas-monitoring arrangement suitable for the task?
- Did the crew receive updated information at handover?
- Could the same condition exist at another well?
Dexur EHS maintains the relationship between the investigation findings and the changes intended to prevent recurrence.
Apply the Correct Regulatory Framework
Upstream oil and gas requires careful applicability review. Drilling, well servicing, production, construction, and offshore activities do not necessarily fall under identical provisions.
| Requirement |
Upstream application |
Records and follow-up |
| OSHA General Industry — 29 CFR Part 1910 |
Applicable onshore extraction and production activities, subject to specific scope provisions. |
Workplace assessments, inspections, training, and corrective records. |
| Hazard Communication — 29 CFR 1910.1200 |
Hazardous drilling additives, treatment chemicals, produced substances, and other covered chemicals. |
Inventories, safety data sheets, labeling, and employee instruction. |
| Air Contaminants — 29 CFR 1910.1000 |
Applicable exposure limits for substances encountered in field operations. |
Exposure assessments, monitoring information, and control measures. |
| Respirable Crystalline Silica — 29 CFR 1910.1053 |
Covered general-industry exposure, including relevant hydraulic-fracturing activities. |
Exposure-control documentation, assessments, engineering controls, and other required records. |
| Respiratory Protection — 29 CFR 1910.134 |
Activities requiring respirators under the applicable exposure or response arrangements. |
Program records, medical evaluation status, fit testing, and training. |
| Occupational Noise Exposure — 29 CFR 1910.95 |
Noise from rigs, pumping equipment, compressors, and other machinery. |
Exposure evaluations and hearing-conservation documentation where required. |
| Machine Guarding — 29 CFR 1910 Subpart O |
Covered moving machinery and power-transmission hazards. |
Guard inspections, defects, repairs, and verification. |
| Walking-Working Surfaces — 29 CFR 1910 Subpart D |
Applicable platforms, access routes, ladders, and fall exposures. |
Inspections, protective arrangements, and findings. |
| Permit-Required Confined Spaces — 29 CFR 1910.146 |
Qualifying spaces within the standard’s scope. |
Evaluations, entry documentation, and required coordination. |
| Construction — 29 CFR Part 1926 |
Activities classified as construction, such as certain facility installation or alteration work. |
Task-specific construction records and safeguards. |
| Recordkeeping — 29 CFR Part 1904 |
Covered occupational injury and illness recording and reporting. |
Recordability decisions, applicable OSHA forms, and supporting case details. |
Determine coverage according to the activity and jurisdiction. OSHA identifies general-industry and other relevant requirements for oil and gas extraction. OSHA: Oil and Gas Extraction Standards
Energy Control: Account for the Drilling and Servicing Exclusion
29 CFR 1910.147 expressly excludes oil and gas well drilling and servicing from its scope. Other covered production or maintenance activities require their own applicability determination.
The exclusion does not make unexpected movement, trapped pressure, or stored energy acceptable. Maintain task-appropriate isolation and verification practices under the requirements applicable to the operation. OSHA: Control of Hazardous Energy
Avoid assigning the same lockout/tagout compliance checklist indiscriminately to a drilling job, a well intervention, and a production-facility maintenance task.
Process Safety Management: Do Not Assume Uniform Coverage
29 CFR 1910.119 excludes oil and gas well drilling or servicing operations. The standard also contains other scope provisions and exemptions, including normally unoccupied remote facilities.
Evaluate other upstream processes against the applicable criteria and OSHA guidance. Neither the presence of hydrocarbons nor an “upstream” label is enough to establish the correct determination. OSHA: Process Safety Management
Where PSM applies, link required recommendations and actions to the covered process. Where it does not, retain the relevant operational risk assessments and equipment-safety records.
Silica: Use the Standard Applicable to Extraction Work
Hydraulic-fracturing sand handling can generate respirable crystalline silica. Assess transfer points, sand-moving equipment, operating methods, and employee exposure.
For covered general-industry operations, use 29 CFR 1910.1053 rather than automatically applying the construction standard’s Table 1 approach. OSHA: General Industry Silica Standard
Hydrogen Sulfide: Base Decisions on Hazard Assessment and Monitoring
Where hydrogen sulfide may be present, maintain the applicable detection, exposure-control, training, and emergency arrangements.
Odor is not a reliable warning method. Document monitor readiness, alarm events, work restrictions, and investigation results. OSHA: Hydrogen Sulfide Safety and Health Hazards
Tank Gauging: Evaluate Hydrocarbon and Oxygen-Deficiency Hazards
Opening production-tank hatches can expose workers to concentrated hydrocarbon gases and vapors and oxygen-deficient atmospheres. This risk is not limited to tanks containing hydrogen sulfide.
Review the need for manual access, alternative gauging or sampling arrangements, and the controls appropriate to the task. Preserve findings by tank, activity, and operating condition. OSHA–NIOSH: Manual Tank Gauging and Sampling Hazard Alert
Distinguish Occupational Safety From Operational Assurance
| Program or record |
Primary purpose |
Relationship to EHS workflows |
| Occupational safety requirements |
Protect workers from machinery, pressure, falls, hazardous atmospheres, and exposure. |
Inspections, investigations, exposure assessments, and corrective work. |
| Well-control procedures and equipment assurance |
Maintain control of the well under the applicable operating requirements. |
Reference technical findings and track resulting actions under the responsible specialists. |
| State oil and gas requirements |
Govern jurisdiction-specific well permitting, construction, operation, and related obligations. |
Record relevant responsibilities and follow-up for each asset. |
| Offshore requirements |
Establish duties under the applicable offshore jurisdiction. |
Organize required assessments, audits, and assigned actions. |
| Operator and industry standards |
Define adopted equipment, operating, or contractual expectations. |
Track findings against the identified requirement and applicable edition. |
For covered U.S. Outer Continental Shelf operations, BSEE’s 30 CFR Part 250, Subparts establishes Safety and Environmental Management Systems requirements. This is a distinct offshore framework and should not be presented as universally applicable to onshore wells. 30 CFR Part 250, Subparts
Prepare Reports for Operational Review
Examples include:
- Pressure-release events by equipment type and job phase
- Dropped-object findings by rig area
- Gas alarms categorized by investigation outcome
- Tank-access concerns awaiting correction
- Silica-control deficiencies by completion activity
- Isolation discrepancies by task
- Recurring component failures across wells
- Outstanding restrictions before equipment reuse
- Incidents associated with simultaneous operations
- Actions transferred between drilling, completion, and production teams