Texas Railroad Commission Form H-9 is the Certificate of Compliance for Statewide Rule 36 (Hydrogen Sulfide) that every oil and gas operator must file to certify that a well, facility, or system handling hydrogen sulfide gas meets the safety rules in 16 Texas Administrative Code §3.36. The operator files it with the Railroad Commission of Texas, and the form puts your name and your company on the line for the safety of the public near your operation.
If you handle sour gas in Texas, this single page tells the state that you know your hydrogen sulfide risk and that you have a plan to protect people from it. The Railroad Commission regulates more than 400,000 oil and gas wells across Texas, and hydrogen sulfide is one of the deadliest hazards in the field — concentrations of just 100 parts per million can be fatal within minutes. Getting Form H-9 wrong does not just mean a rejected filing; it can mean an operation that runs without proper safety planning near homes, roads, or schools.
In this guide, you will learn:
- 🛠️ How to fill out every line and box on Form H-9 the right way
- 📋 What documents and numbers to gather before you open the form
- 🧑🔧 Three full filled-out examples using real operator scenarios
- 🚫 The most common mistakes that get an H-9 rejected or flagged
- 📨 How to file online and by hard copy, with deadlines and proof to keep
The current version of Form H-9 carries a revision tied to the July 2019 online-filing launch, so confirm the revision date printed on the official PDF before you start. This article uses the exact field names and item numbers printed on that form so you can follow along line by line.
What Form H-9 Is and Who Must File It
Form H-9 is the Statewide Rule 36 Certificate of Compliance, and it certifies that an operator has complied, or will comply, with the hydrogen sulfide safety rule found in 16 TAC §3.36. Hydrogen sulfide, also called H2S or sour gas, is a colorless, toxic gas that smells like rotten eggs at low levels but deadens your sense of smell at high levels. Statewide Rule 36 forces operators to identify where this gas exists, measure how far it could spread, and build a contingency plan to protect the public.
You must file Form H-9 if you operate any well, gathering line, plant, or facility that handles gas containing 100 parts per million or more of hydrogen sulfide and that sits in or near a public area. The operator of record — the company holding the Form P-5 Organization Report — is the party responsible for filing. This includes drilling operators, production operators, saltwater disposal operators, and plant operators.
The certificate is non-transferable, which is a detail many new operators miss. When you buy a lease, a well, or a plant, the prior operator’s H-9 does not move to you. A new operator of a system, or of any acquired element of a system, must file a fresh certificate to cover that operation under their own name.
Statewide Rule 36 connects several agencies and rules. The Railroad Commission’s Oil and Gas Division receives and reviews the form, while Texas Natural Resources Code §91.143 supplies the criminal penalty for filing a false certificate. Filing Form H-9 also often travels with the Form W-1 Drilling Permit when the drilling sits in a Rule 36 area.
Before You Start: Documents and Information You Need
Filling out Form H-9 goes faster when you gather your data first, because the form asks for technical numbers you cannot guess. Pull these items together before you open the form, since a missing number is the top reason filers stall halfway through.
- Your RRC Operator Number (P-5 number). This unique number is assigned to each company that files a Form P-5, and it appears at the bottom of each page of your proration schedule; without it the form cannot be matched to your organization.
- The RRC ID or Registration Numbers for each operation. You need the oil lease number, gas well number, drilling permit number, API number, plant ID, or pipeline permit number for every element you are certifying, because the form ties the certificate to those exact IDs.
- Operator name, address, and contact. The state mails notices and findings here, so an old address means you miss deadlines and responses.
- Maximum H2S concentration in the system. Measured in parts per million, this drives whether the form even applies and what your radius of exposure will be.
- Maximum gas volume available for escape. Stated in cubic feet per day, this number feeds the radius-of-exposure math under Rule 36.
- The calculated radius of exposure. Rule 36 uses set formulas to convert concentration and volume into a distance in feet; you must compute this before filing.
- A written contingency plan with a physical delivery address. Rule 36 requires a plan to protect the public, and the form asks where the plan and test data are kept — a street address, never a post office box.
- A description of the operation. You need a clear statement of what you are certifying (a drilling well, a disposal well, a gathering system, a plant) so the reviewer knows exactly what the certificate covers.
- Your qualified signer’s name and title. The rule requires the certificate be executed by a person qualified through training and experience, so identify that person early.
If any one of these is missing, the form either cannot be submitted or it can be submitted wrong, which exposes you to a rejected filing or a false-certification problem down the road.
Where to Get the Form and How to Access It
You can get Form H-9 in two ways, and the Railroad Commission now strongly pushes the online route. The blank PDF lives on the RRC Oil & Gas Forms page, where you can download and print it for a hard-copy filing. The form sits alphabetically in the “H” series alongside related hydrogen sulfide and injection forms.
The faster path is the RRC Online System, which lets you file Form H-9 electronically as part of the state’s Texas Oilfield Relief Initiative. To file online, your company first needs an account, and your organization’s security administrator must assign you filing rights through their administration account. If your company has no security administrator yet, you set that up through the online filing at RRC instructions page.
For step-by-step screens, the Commission publishes a dedicated H-9 User Guide that walks through the online certificate of compliance flow. Records filed online after July 15, 2019 also appear in the public H-9 Certificate of Compliance Query, while older paper filings live in the RRC’s imaged records (Neubus) system.
A common misconception is that the form must be filed online. That is false — the Commission still accepts hard-copy filings, but it highly encourages online filing to save staff time and speed up review. Whichever channel you pick, the field-by-field content below is identical.
Step-by-Step: How to Fill Out Form H-9 Line by Line
This section is the heart of the form. Each box below is broken down with what it asks, how to answer, an example entry, the edge case to watch, the mistake that hurts you, and the myth to drop. Use the exact item numbers printed on the official form as your guide.
Item: Operator Name
What it asks in plain English. This box wants the legal name of the company that operates the well or facility you are certifying.
How to answer it. Enter your full legal operator name exactly as it appears on your Form P-5 Organization Report, in all capital letters where the form uses caps. Do not use a nickname, a “doing business as” shorthand, or a parent-company name that differs from your P-5.
A specific example answer. Permian operator LONE STAR SOUR GAS OPERATING, LLC writes its name precisely as it reads on its P-5.
A nuance or edge case. If your company recently changed names through a P-5 amendment, use the new legal name and make sure the P-5 update has cleared first, or the system will not match your record.
A common mistake and its consequence. Writing a name that does not match your P-5 record breaks the link between the certificate and your organization, which can stall acceptance until you correct it.
A misconception about this field. Some filers think the operator name can be the field name or lease name; it cannot, because the certificate attaches to the operating company, not the property.
Item: Operator Number (P-5 Number)
What it asks in plain English. This box wants your unique six-digit Railroad Commission operator number.
How to answer it. Enter the number assigned to your company when you filed your Form P-5; you can find it at the bottom of each page of the operator’s copy of the proration schedule.
A specific example answer. Lone Star’s compliance manager enters 123456 as the operator number.
A nuance or edge case. If you operate under more than one entity, confirm you are using the number for the entity that actually holds the lease or permit being certified, not a sister company.
A common mistake and its consequence. Transposing two digits points the certificate at the wrong company or no company at all, which causes a mismatch and a delay.
A misconception about this field. Filers sometimes confuse the operator number with a lease or API number; they are different identifiers and cannot be swapped.
Item: Operator Address
What it asks in plain English. This is the mailing address where the Commission can reach your company.
How to answer it. Enter your current business street or mailing address, including city, state, and ZIP code, written clearly so notices reach you.
A specific example answer. Lone Star enters 4400 Energy Plaza, Suite 210, Midland, TX 79701.
A nuance or edge case. If your company address changed, remember that any change in operator address requires an amended H-9, so keep this field current across all your certificates.
A common mistake and its consequence. An outdated address means Commission notices, including requests to fix problems, go to the wrong place and you miss your window to respond.
A misconception about this field. Some assume the address can be a P.O. box; for the contingency-plan location that is banned, and for the operator address you still want a reachable, current address.
Items 13–16: Maximum Volume and Concentration
What it asks in plain English. These boxes ask for the maximum gas volume and the maximum hydrogen sulfide concentration that are available for escape from the system.
How to answer it. Enter the maximum gas volume in cubic feet per day and the maximum H2S concentration in parts per million, based on the worst-case amounts within the system available for escape. If the system to be certified is a vacuum system and no gas could possibly escape, fill Item 14 with 0-Vacuum.
A specific example answer. For a sour gas well flowing 1.2 million cubic feet per day at 5,000 ppm H2S, the filer enters 1,200,000 for volume and 5,000 for concentration.
A nuance or edge case. A true vacuum gathering system gets the 0-Vacuum entry in Item 14 because there is no positive pressure to push gas out into the air.
A common mistake and its consequence. Entering average instead of maximum figures understates your risk and produces a radius of exposure that is too small, which undermines the safety basis of the whole certificate.
A misconception about this field. Operators think low average production means a low number here; the form wants the maximum available for escape, not the typical day.
Items 21–22: Radius of Exposure
What it asks in plain English. These boxes ask how far the toxic gas could reach if it escaped — the radius of exposure measured from the source.
How to answer it. Calculate the radius of exposure using the Statewide Rule 36 formula, based on the maximum effect of any element within the system, and enter the distance in feet.
A specific example answer. Using the worst-case volume and concentration above, the engineer computes a 100-ppm radius of exposure of 3,000 feet and enters that figure.
A nuance or edge case. When a system has several elements, base Items 21 and 22 on the element that produces the largest radius, not an average across the system.
A common mistake and its consequence. Calculating the radius from only one well in a multi-element system can leave nearby public areas uncovered, defeating the protection the rule requires.
A misconception about this field. Filers believe the radius is a fixed company number; it changes with volume and concentration, so each operation needs its own calculation.
Item 23: Produced Water and Free Gas
What it asks in plain English. This box asks whether your operation involves the kind of fluid handling that triggers a “yes” under the rule.
How to answer it. Mark the box based on your actual operation, and remember that disposal of produced water with little or no free gas does not require a “yes” entry in Item 23.
A specific example answer. A saltwater disposal operator injecting produced water with negligible free gas enters No in Item 23.
A nuance or edge case. If your disposal stream carries meaningful free gas with H2S, the calculus changes and you may need the “yes” path and a fuller certification.
A common mistake and its consequence. Checking “yes” out of caution on a clean produced-water disposal can over-complicate your filing and invite questions you do not need to answer.
A misconception about this field. People assume any saltwater disposal triggers a “yes”; the free-gas content is what matters, not the water itself.
Item: Railroad Commission ID or Registration Numbers and Type Codes
What it asks in plain English. This section lists every operation you are certifying and tags each one with the right ID type.
How to answer it. Show each RRC ID or Registration Number and identify its type using the printed codes: 1 for Oil Lease Number, 2 for Gas Well Number, 3 for Pipeline Permit Number, 4 for Plant I.D. Number, 5 for Drilling Permit Number, 16 for API Number, and 9 for Other (Explain). If you run out of room, attach an additional 8½ x 11 sheet.
A specific example answer. A driller enters drilling permit number 812345 tagged with type code 5, and adds the API number 42-329-12345 tagged with code 16.
A nuance or edge case. One certificate can cover a single operation or multiple operations in an area, field, or group of fields within one Commission District, so list each ID that belongs under the certificate.
A common mistake and its consequence. Using the wrong type code, like tagging an API number as a lease number, miscategorizes the operation and can scramble how the certificate is recorded.
A misconception about this field. Filers think one ID covers everything; an amended H-9 is required any time you add or delete an RRC ID or Registration Number under a certificate.
Item: Location of Contingency Plan and Test Data
What it asks in plain English. This box asks where your written hydrogen sulfide contingency plan and supporting test data are physically kept.
How to answer it. Enter a real delivery address — a street address where someone could hand-deliver a document — and never a post office box.
A specific example answer. Lone Star enters 4400 Energy Plaza, Suite 210, Midland, TX 79701 as the location of its plan and test data.
A nuance or edge case. If you move the plan to a new field office, you must file an amended H-9, because any change in the location of the contingency plan or test data requires an amended certificate.
A common mistake and its consequence. Entering a P.O. box violates the instruction outright and can get the field flagged, because inspectors need a place they can actually reach the plan.
A misconception about this field. Operators assume the plan can live only at headquarters; it can live anywhere reachable, as long as you list a true delivery address.
Item: Description of Operation
What it asks in plain English. This box asks you to describe, in clear terms, exactly what kind of operation the certificate covers.
How to answer it. Write a complete description so it is obvious which element of an operation the certificate covers — for example, drilling, production, gathering, disposal, or a plant.
A specific example answer. A disposal operator writes Saltwater disposal well, injection of produced water into nonproductive zone.
A nuance or edge case. When one certificate covers several operations in a field, describe the type of operation broadly enough to cover them all yet specific enough that the reviewer sees what is included.
A common mistake and its consequence. A vague description like “oil and gas” leaves the reviewer guessing, which can delay acceptance or leave part of your operation uncertified.
A misconception about this field. Filers think the description is just a label; it actually defines the legal scope of what your certificate protects.
Item: Reason for Amended Filing
What it asks in plain English. When you are amending an existing certificate, this is where you say why.
How to answer it. If this is an amended filing, indicate the reason in the Other Explanation space — for example, a change in operator, address, radius of exposure, or added RRC ID.
A specific example answer. An operator amending after a name change writes Amended: change in operator name per P-5 amendment.
A nuance or edge case. A modification that increases the radius of exposure to include additional public areas requires an amended certificate, and a change in public exposure from infringement on an existing radius must be filed within 30 days.
A common mistake and its consequence. Leaving this blank on an amended filing leaves the reviewer unable to see what changed, which can bounce the amendment back.
A misconception about this field. People think small changes need no amendment; even an address or plan-location change triggers an amended H-9.
Item: Certification and Signature
What it asks in plain English. This is the legal sign-off where a qualified person swears the certificate is true.
How to answer it. A party who is qualified through training and experience signs and dates the certificate, declaring under the penalties in Section 91.143 of the Natural Resources Code that they are authorized to make the report and that it is true.
A specific example answer. Maria Delgado, HSE Manager, signs and dates the form 03/14/2026, because she is trained in H2S safety and authorized to certify for the company.
A nuance or edge case. If your usual signer leaves, do not let an unqualified clerk sign; the rule specifically requires a qualified party to execute the certificate.
A common mistake and its consequence. Signing when the data is wrong or unverified exposes the signer to penalties under Natural Resources Code §91.143 for a false certificate.
A misconception about this field. Filers think the signature is a formality; it is a sworn legal declaration with criminal exposure for false statements.
Three Filled-Out Examples Using Real Scenarios
These three scenarios follow three operators through Form H-9 from start to finish. Each table shows what the operator enters in the form’s key sections.
Scenario 1 — Lone Star Sour Gas Operating drills a new sour gas well. Maria Delgado certifies a new drilling operation in an H2S area before spudding the well.
| Form Section | What Lone Star Enters |
|---|---|
| Operator Name | LONE STAR SOUR GAS OPERATING, LLC |
| Operator Number | 123456 |
| Operator Address | 4400 Energy Plaza, Suite 210, Midland, TX 79701 |
| Items 13–16 (Max Volume / Concentration) | 1,200,000 cf/d and 5,000 ppm |
| Items 21–22 (Radius of Exposure) | 3,000 feet (100-ppm radius) |
| Item 23 (Produced Water/Free Gas) | No |
| RRC ID and Type Code | Drilling permit 812345, type 5; API 42-329-12345, type 16 |
| Location of Contingency Plan | 4400 Energy Plaza, Suite 210, Midland, TX 79701 |
| Description of Operation | Drilling, new sour gas well in Rule 36 area |
| Signature | Maria Delgado, HSE Manager, 03/14/2026 |
Scenario 2 — Pecos Disposal Services certifies a saltwater disposal well. Carlos Rivera certifies an injection well that disposes of produced water with little free gas.
| Form Section | What Pecos Disposal Enters |
|---|---|
| Operator Name | PECOS DISPOSAL SERVICES, INC. |
| Operator Number | 654321 |
| Operator Address | 901 Caprock Road, Pecos, TX 79772 |
| Items 13–16 (Max Volume / Concentration) | Minimal free gas; H2S 250 ppm |
| Items 21–22 (Radius of Exposure) | 1,000 feet |
| Item 23 (Produced Water/Free Gas) | No (little or no free gas) |
| RRC ID and Type Code | Plant/disposal ID, type 4; oil lease 067890, type 1 |
| Location of Contingency Plan | 901 Caprock Road, Pecos, TX 79772 |
| Description of Operation | Saltwater disposal, injection of produced water into nonproductive zone |
| Signature | Carlos Rivera, Operations Supervisor, 02/02/2026 |
Scenario 3 — Big Bend Gathering files an amended H-9 after buying a system. Janet Cole files a fresh certificate because the prior operator’s H-9 does not transfer.
| Form Section | What Big Bend Gathering Enters |
|---|---|
| Operator Name | BIG BEND GATHERING, LP |
| Operator Number | 778899 |
| Operator Address | 55 Terlingua Highway, Alpine, TX 79830 |
| Items 13–16 (Max Volume / Concentration) | 3,500,000 cf/d and 8,000 ppm |
| Items 21–22 (Radius of Exposure) | 5,280 feet (largest element governs) |
| Item 23 (Produced Water/Free Gas) | No |
| RRC ID and Type Code | Pipeline permit 04567, type 3 |
| Location of Contingency Plan | 55 Terlingua Highway, Alpine, TX 79830 |
| Description of Operation | Sour gas gathering system, acquired from prior operator |
| Reason for Amended Filing | New operator after acquisition; certificate non-transferable |
How to File the Completed Form
Form H-9 can be filed two ways, and each has its own steps, timing, and proof to keep. The Commission urges operators to file online, but it still accepts hard copies.
Online through the RRC Online System. File electronically at the RRC Online System login. There is no filing fee for the H-9 itself, and you need an RRC Online account with filing rights granted by your company’s security administrator. Online filings are processed faster, appear in the public H-9 query after submission, and give you an on-screen confirmation — save or print that confirmation as your proof of filing.
Hard copy at the District Office. File the certificate in triplicate at the Commission District Office where the operation is located, using the printed official form. There is no fee, and accepted submission is by mail or in person at the correct district office. Processing takes longer than online, so keep a stamped or date-marked copy as your proof of filing.
Timing rules that govern both channels. For new or modified facilities not covered by an existing certificate, file at least 30 days before you start the operation or construction. In extenuating circumstances, you may file with a written explanation requesting waiver of the 30-day rule, and approval of the certificate then serves as authority to proceed. If you have questions, the Oil and Gas Division’s Field Operations department can be reached at OG_FOPS@rrc.texas.gov or 512-463-6838.
What Happens After You File
Once you file, the Railroad Commission’s Oil and Gas Division reviews the certificate to confirm it certifies compliance with Statewide Rule 36. For new or modified facilities, the certificate states that you will be in compliance upon completion, or in compliance per an attached schedule, so the Commission checks that your description and data support that claim.
If you filed online, your certificate appears in the H-9 Certificate of Compliance Query for records submitted after July 15, 2019, which gives you and the public a way to confirm it is on file. Approval of a certificate filed under the extenuating-circumstances waiver constitutes your authority to proceed with the operation.
Your duty does not end at filing. Forms H-9 filed for drilling or workover must be amended within one year to show the disposition of the well, and that amendment must include the prior certificate number, the current RRC ID number, or, if the well is a dry hole, the date the Form W-3 Plugging Record was filed. Any later change to operator, address, plan location, radius, or covered IDs triggers a new amended certificate.
Mistakes to Avoid When Filling Out the Form
Each error below has a direct consequence, so check your form against this list before you sign.
- Using a name that does not match your P-5. The certificate cannot be tied to your organization and acceptance stalls.
- Entering the wrong operator number. The filing points at the wrong company or none at all, causing a mismatch.
- Using average instead of maximum volume or concentration. Your radius of exposure comes out too small and the safety basis fails.
- Forgetting the “0-Vacuum” entry on a vacuum system. Item 14 is incomplete and the reviewer cannot tell gas cannot escape.
- Calculating radius from one element in a multi-element system. Nearby public areas may go uncovered, defeating the rule.
- Checking “yes” on Item 23 for clean produced-water disposal. You over-complicate a filing that needs a “no.”
- Using the wrong RRC ID type code. The operation is miscategorized and the record is scrambled.
- Listing a P.O. box for the contingency-plan location. This violates the instruction and gets the field flagged.
- Writing a vague operation description. Part of your operation may go uncertified and acceptance is delayed.
- Leaving the amendment reason blank. The reviewer cannot see what changed and the amendment bounces back.
- Assuming the prior operator’s H-9 transfers. The certificate is non-transferable and your new operation runs uncertified.
- Filing late. Missing the 30-day-prior rule means you start an operation without an approved certificate.
Do’s and Don’ts
Do:
- Do file at least 30 days before starting a new or modified operation, because that is the rule’s deadline.
- Do use maximum values in Items 13–16, because the radius of exposure depends on worst-case figures.
- Do list a real street address for the contingency plan, because P.O. boxes are banned.
- Do file a new certificate when you acquire a system, because H-9s are non-transferable.
- Do amend a drilling H-9 within one year, because the rule requires you to show well disposition.
- Do save your confirmation or stamped copy, because it is your proof of filing.
Don’t:
- Don’t let an unqualified person sign, because the rule requires a qualified signer.
- Don’t guess your H2S numbers, because false data exposes you to penalties.
- Don’t skip an amendment for an address change, because that change requires one.
- Don’t mix up ID type codes, because miscoding scrambles your record.
- Don’t ignore the one-year drilling amendment, because it tracks well disposition.
- Don’t assume online filing is required, because hard copy is still accepted.
Filing on Your Own vs. With Professional Help
Many small operators file Form H-9 in-house, while larger companies and complex sour-gas systems often lean on engineers or consultants. The table below frames the trade-off.
| Filing on Your Own | Filing With Professional Help |
|---|---|
| Costs nothing beyond staff time, since there is no filing fee | Adds consultant or engineering cost on top of staff time |
| Works well for simple, low-concentration operations you understand | Worth it for complex multi-element systems with large exposure |
| Keeps full control of timing so you can hit the 30-day deadline | Brings expertise in radius-of-exposure math that reduces error |
| Builds your team’s internal knowledge of Rule 36 | Reduces risk of false certification under §91.143 |
| Faster for routine amendments like an address change | Helpful when public areas fall inside your radius of exposure |
Pros of filing on your own: no fee, full control, faster routine amendments, internal knowledge growth, and direct ownership of your compliance.
Cons of filing on your own: higher risk on the radius math, exposure if your H2S data is off, time spent learning the form, possible miscoding of IDs, and personal penalty risk on the signature.
FAQs
Who has to file Form H-9?
Yes, any oil and gas operator handling gas with 100 ppm or more hydrogen sulfide near a public area must file to certify compliance with Statewide Rule 36.
Is there a fee to file Form H-9?
No, the Railroad Commission charges no filing fee for Form H-9 whether you file online or by hard copy.
Can I file Form H-9 online?
Yes, you can file through the RRC Online System, which the Commission encourages, though hard-copy filing at the District Office is still accepted.
Does the prior operator’s H-9 transfer to me when I buy a lease?
No, certificates are non-transferable, so a new operator of any acquired system or element must file a fresh certificate.
How many copies do I file by hard copy?
Yes, you must file the certificate in triplicate at the Commission District Office where the operation is located.
When is Form H-9 due for a new operation?
Yes, file at least 30 days before you start the operation or construction for new or modified facilities not covered by an existing certificate.
Do I write the lease name or the company name in the Operator Name box?
No, you write your legal operator name as it appears on your Form P-5, not the lease or field name.
What do I put in Item 14 for a vacuum system?
Yes, if no gas could escape from a vacuum system, you fill Item 14 with “0-Vacuum.”
Does saltwater disposal always require a “yes” in Item 23?
No, disposal of produced water with little or no free gas does not require a “yes” entry in Item 23.
Can I list a P.O. box for the contingency-plan location?
No, that field requires a true delivery street address, never a post office box.
Which type code do I use for an API number?
Yes, you tag an API number with type code 16, while a drilling permit uses code 5 and an oil lease uses code 1.
Do I have to amend a drilling H-9 later?
Yes, an H-9 filed for drilling or workover must be amended within one year to show the well’s disposition.
Does an address change require an amended H-9?
Yes, any change in operator address or in the location of the contingency plan or test data requires an amended certificate.
Can anyone in the office sign Form H-9?
No, the certificate must be prepared and executed by a person qualified through training and experience to make the certification.
What happens if I file a false certificate?
No, you should never do that, because the signature is sworn under Natural Resources Code §91.143, which carries penalties for false certification.
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