Worker Guide

HazCom at the Wellsite: SDS, Labels and the Chemicals in Every Tank

Hazard communication is the rule that makes sure the people working around chemicals know what they are handling. On a well location, that means the worker has a right to know what is in the tanks, drums, and lines they work around. The employer has to make that information available and understandable, before the work starts, in plain terms a worker can act on.

What hazard communication means on location

Hazard communication starts with a simple idea: a worker cannot protect themselves from a chemical they do not know is there. The person who opens a thief hatch, cuts into a flow line, or mixes a drum of additive has to be told what they are opening. That information has to come from the operator and the contractor both, because each one has workers on location who can come in contact with chemicals.

Hazard communication is not the same as the rules for moving chemicals. When crude, acid, or other products travel by truck, the hazmat transportation rules control how they are packed, marked, and documented. The hazard communication rule takes over where the work happens, at the tanks, drums, and lines on the lease, and it stays in force as long as the chemical is there.

The chemicals the rule covers

The rule covers any chemical that can hurt a worker or start a fire. That includes chemicals that are a physical hazard, like ones that burn easily or react violently, and chemicals that are a health hazard, like ones that can burn skin, poison a person, or damage the lungs. Under that definition, almost everything handled on a location counts.

Crude and condensate give off vapors that can catch fire. Acid can burn skin and eyes. Methanol is flammable and poisonous if a worker swallows it or breathes the vapor. Corrosion inhibitors and the dozens of additives blended into treating fluids can be hazards in their own right. None of these are exotic. They are the everyday contents of the tanks, totes, and barrels on a lease, and the rule treats every one of them as a hazardous chemical. When products like these are used to control corrosion and scale downhole or in surface equipment, the work also falls under chemical treating practices.

The three pieces of a hazard communication program

The first piece is the written hazard communication program. The employer writes down how chemicals are handled on that location: who keeps the safety data sheets, which containers get labeled, and how workers are trained. The written program has to be available to workers who ask for it. It is not a binder that sits in the office. It is the plan for how the rule actually runs in the field.

The second piece is the label on the container. Every drum, tank, and cylinder of a hazardous chemical gets a label that tells a worker the hazard at a glance. Labels built to the globally harmonized system carry pictograms, the diamond-shaped symbols that show the hazard class, plus a signal word and hazard and precautionary statements. The worker does not have to study the chemical to learn the drum is flammable. The label says so up front.

The third piece is the safety data sheet, the SDS. Where the label is the short answer, the SDS is the full file on the chemical: what it is, what it can do, what to do in an emergency, and how to handle it. The SDS is the detail behind the label, and it has to be on hand for every hazardous chemical on the location.

The 16-section safety data sheet

An SDS is not written in whatever order the supplier chooses. Under the globally harmonized system, which OSHA adopted for its hazard communication rule, every SDS has the same sixteen sections in the same order. A worker who learns the layout can find the same information in any SDS from any supplier.

Sections one through eight cover the day to day basics: what the chemical is and who makes it, the hazards, what is in it, first aid, fire fighting, what to do if it spills, safe handling and storage, and exposure limits with the personal protection to use. Sections nine through sixteen carry the technical detail, such as physical and chemical properties, stability and reactivity, toxicology, disposal, and transport information.

For field use, most workers need a few sections most of the time. Section two lists the hazards. Section four gives first aid. Section six tells what to do when it spills. Section seven covers handling and storage, and section eight lists exposure limits and the personal protective equipment to wear. Find the chemical's SDS before the job starts, not after something goes wrong.

Labels matter most when chemicals change containers

A drum arrives from the supplier with a full label, and that label does its job as long as the drum stays whole. The moment someone transfers chemical out of that drum into a smaller field container, a jug, a bucket, or a day tank, the small container becomes a labeled container too. It has to carry the same information so the next person who picks it up knows what is inside. There are narrow exceptions, mainly the worker who did the transfer and uses the chemical immediately, but those exceptions end the moment the container is set down for someone else to use.

Labels wear out. They get sprayed over, torn, or washed off, and containers get reused for something new. An unlabeled container on a location is a question that has to be answered before anyone opens it. When in doubt, treat the contents as hazardous and ask where the SDS is.

Training ties the whole program together. Every worker who may be exposed to hazardous chemicals has to be trained before the first assignment, and again when the hazard changes. Training covers how to read a label, how to use the sixteen-section SDS, and where the SDS are kept on that location. Chemical inventories and training records are the kind of document trail tracked in OpsFlo, ticket, dispatch, timesheet, approvals, and document software built for field crews. When those records are current, a new hand can be shown the SDS and the training file before they touch a chemical.

Sources and further reading

• eCFR 1910.1200: Hazard communication
• OSHA: Hazard communication standard