Texas Railroad Commission Rule 36 In Oil Production
Philip Blake, Safety Consulting, Inc.
Rule 36 of the Texas Railroad Commission is rapidly being recognized as one of the most, perhaps the most significant safety regulation of the post-OSHA era. Until the initial publication of Rule 36 in 1975 the many hazards of HIS were only vaguely understood and no regulation for positive control of the gas existed. It covers drilling operations as well as production and provides that every operator have written operating and training plans to protect both employees and the general public from uncontrolled gas leakage. It provides a workable mathematical formula for computing gas dispersion. Since its final issue in 1976, Rule 36 has become a model for similar state oil and gas regulations in numerous states and was one of the principal sources of data for the proposed safety standard recommended by NIOSH. Its scope and thoroughness make it a landmark.