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Companies frequently ask us how often they should be testing their crude oil. Chemscape recommends a best practice of sampling your crude oil annually. A new well, formation, or process change can trigger the need for resampling. A production change, well stimulation in the depth of drilling can also trigger the need for sampling. The samples need to be sent to an accredited lab, with experience in the oil and gas industry. TDG regulations are separate from WHMIS classifications and changes in the composition of the crude oil may require updating the TDG classification. Aside from seasonal variations to composition and blending most crude products are retested for TDG purposes on an annual basis; significant changes may warrant SDS reauthoring.  A TDG proof of classification document is recommended to provide the result according to the last sample date.

Typically, produced water is non-hazardous. If it is determined that your produced water is a hazardous material (e.g., corrosive, toxic, flammable), then an SDS is an appropriate means of communicating the hazard to workers, haulers and the product receivers. It is certainly best practice to have a Safety Data Sheet for TDG purposes even if the product is not classified for TDG, to prove to inspectors this has been considered.

Blends are mixtures, GHS has a whole section on the classification of mixtures. In absence of analytical data on the blended product, you need to consider the toxicity of the parent components and combine or assume the hazards of the most hazardous components. The producer of a product is responsible for communicating the hazards of their product; they do this through their SDS. If you change the composition of the product by blending it with other materials, you are responsible for communication the hazards of the new material.

You can certainly use sampling data from on site monitoring systems. This is quite common for gas streams.

For practical purposes, it is a good idea to minimize the number the number of SDS you need to manage. If the composition and physical characteristics are within a range that produces the same hazard classification and transportation classification, the SDS can be combined. Having an SDS created for each sample or site will soon become unmanageable.

The ASTM-86 test method is not appropriate for crude products that contain ‘light ends’ or extremely volatile chemicals (e.g. propane, butane, pentane).