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FAQs


Click one of the FAQs icons below to view that program’s most frequently asked questions.


WCE Faq
SPPE Faq
ISD Faq

General FAQs

  • Why was SafeOCS established?

    SafeOCS was established to close a gap in safety data and information sharing among industry groups. Almost all oil and gas companies operating on the OCS have internal safety data reporting programs. However, due to legal and commercial concerns, these data are not being shared widely among stakeholders. SafeOCS provides a solution to these concerns by offering operators a confidential method to share important equipment failure and safety data. The aggregated data can be used to reduce the risk of major events, including loss of life or property and environmental harm.

    Information collected through the SafeOCS program will help identify current safety issues and emerging trends. Other industries, such as aviation, have shared information through similar industry-wide programs that have led to increased operational safety and protection of the environment.

  • How does the SafeOCS program differ from other safety data reporting programs managed by individual companies or industry groups?

    Information from reporting programs operated by individual companies is generally not shared across the industry. Safety information collected by industry groups is often limited to the group's members and is limited in scope.

    The goal of SafeOCS is to gather, aggregate, analyze and publish a broad scope of safety and equipment reliability data from all segments of OCS operations, for use by industry, government, and the public. SafeOCS will complement other safety and equipment reliability efforts and add to the combined knowledge to make the OCS a safer place to work and operate.

    To facilitate the submission of information to SafeOCS, BTS has worked closely with the industry to ensure that BTS systems closely mirror industry data reporting processes.

  • What happens to the information submitted to SafeOCS and how will it be used?

    The reports and information submitted to SafeOCS are collected by BTS staff and confidential information is secured. The information goes through a detailed quality evaluation and statistical analysis. It is then aggregated so that industry-wide patterns and results can be discerned. This aggregated information is then shared in a report with all stakeholders. The information can be used to improve safety and equipment reliability on the OCS.

  • How do I know my information is confidential and secure?

    BTS operates SafeOCS under the Confidential Information Protection and Statistical Efficiency Act (CIPSEA) (44 U.S.C. § 3501 note). Under CIPSEA, it is a felony, punishable by up to $250,000 in fines and up to 5 years in jail, for BTS or its agents to release identifiable data confidentially submitted in reports by individuals, companies or other entities. BTS has very strict protocols in place for collecting and protecting such data. CIPSEA protections include, but are not limited to:

    • protection from subpoenas and Freedom of Information Act disclosure
    • protection from release to the public, BSEE, or any other government agency
    • protection from uses other than statistical purposes
  • How does SafeOCS relate to the SEMS Subpart S requirements?

    BSEE's safety and environmental management system (SEMS) rules require facility management to investigate events that have the potential for serious safety or environmental consequences, but the results of these investigations are typically not required to be reported to BSEE or otherwise shared (at 30 C.F.R. Part 250 Subpart S). Note that the investigation results are required to be documented for use in the next hazard analysis or audit. SafeOCS will complement the SEMS requirements by covering a broader scope of equipment failure, near miss, and other safety-related events from an OCS-wide perspective; sharing the results with stakeholders and the public; and adding to the body of information that will make the OCS a safer place to work and operate.

  • Who is the BTS?
    • The Bureau of Transportation Statistics (BTS) was established in 1992 as an independent Federal statistical agency within the U.S. Department of Transportation with the mission to serve the public and other Federal agencies
    • As a Federal statistical agency, BTS’ primary function is the compilation and analysis of relevant and accurate data and the dissemination of information for statistical purposes, thereby allowing the users to make informed decisions
    • Principles for all Federal statistical agencies include relevance to policy issues, credibility among data users, trust among data providers, and independence from political or other undue external influence
    • BTS is policy-neutral (i.e., an objective broker for the facts)
    • BTS is not a regulatory agency and has no authority to issue fines or penalties
    • BTS has authority and obligation per statute and CIPSEA to protect confidentiality of data
  • Why CIPSEA Protection?
    • In 2002, Congress passed into law the Confidential Information Protection and Statistical Efficiency Act (CIPSEA)
    • Stipulates that an agency may collect information under pledge of confidentiality for statistical purposes
    • CIPSEA protections include:
      • o    No government agency may require, for any reason, a copy of a respondent’s report
      • o    Court cannot require a copy of any respondent’s report
      • o    Reports are immune from the legal process and cannot be admitted as evidence
      • o    Reports are exempt from Freedom of Information Act (FOIA) requests
      • o    Information may not be disclosed in identifiable form for any non-statistical purpose without the informed consent of a respondent
    • Willful disclosure of confidential information by Federal employees, agents, and contractors may incur sanctions and penalties o Breach of confidentiality can occur through either direct (names, telephone numbers, etc.) or indirect identifiers (geographical location, equipment, linking of electronic files, etc.)
    • Data requiring confidentiality protection include sensitivity, proprietary, or private data; examples include:
      • o   Original SafeOCS reports provided directly to BTS
      • o    Any BTS working documents
      • o    Sections of root cause analysis reports development by designated subject matter experts
      • o    All of the above whether paper or electronic
    • Non-confidential information includes preventative safety actions recommended for implementation by subject matter experts or stakeholders, and any documents developed for public dissemination using confidential data (e.g., annual reports of aggregated data to stakeholders)
    • Federal statistical agencies can designate agents to assist in data collection
  • What is a Non-Disclosure Agreement?
    • Addresses conduct and responsibilities of BTS staff, contractors, and agents
    • Ensures that no one outside of designated BTS staff, contractors, and agents has access to confidential data
    • Requires individuals accessing detailed data to understand responsibility and obligation to protect confidential information, and adhere to BTS confidentiality procedures
    • Requires completion of annual confidentiality training provided by BTS

WCE FAQs

  • Who must submit a report?

    BSEE requires all oil and gas operators on the OCS to report failures of well control equipment (WCE) under 30 CFR § 250.730(c) of BSEE's Well Control Rule. Under the rule, operators must submit WCE failure reports directly to BTS as BSEE's designee under regulations for collecting WCE failure data and reports.

    Operators must also follow the failure reporting procedures contained in API Standard 53 (incorporated by reference in 30 CFR § 250.198).

  • What must be reported?

    All failures of well control equipment and SPPE must be reported. An equipment failure is any condition that prevents the equipment from meeting the functional specification or purpose.

  • When should a report be submitted?

    A written notice of equipment failure must be provided within 30 days after discovering and identifying the failure. An investigation and a failure analysis must also be performed within 120 days of the failure to determine the cause of the failure.

  • How should reports be submitted?

    Please follow the link below to submit a report:

        •   Well Control Equipment

    You will need to submit information on the event, equipment, lease/company, and other pertinent information. Submit all reports and follow-up investigations to BTS.

  • What additional protections are offered by submitting equipment failure reports to BTS rather than directly to BSEE?

    BTS operates the SafeOCS reporting system. All reports submitted to BTS for inclusion in SafeOCS are accessible only by BTS authorized personnel and BTS-designated agents under CIPSEA. BSEE does not have access to reports you submit to BTS.

    As an independent federal statistical agency, BTS has the authority and obligation under CIPSEA and the agency's authorizing statute to protect the confidentiality of your data, including but not limited to company information, personally identifiable information, and sensitive or proprietary information. By submitting to BTS, your data are protected from release to the public, BSEE, and other non-CIPSEA federal agencies. Data are also protected from subpoenas and Freedom of Information Act requests.

    In contrast, equipment failure reports submitted directly to BSEE do not receive CIPSEA protections and could be subject to release under the FOIA or other authority.

  • What information is shared with BSEE?

    When you submit a notice of equipment failure to SafeOCS, BTS sends an automated email to BSEE with only the following information: date, company name, company ID (if available), and event reference number. Click here for an example email notification to BSEE.

    BTS shares this information with BSEE to demonstrate that operators are complying with the regulation without sharing the details of the reports, which are CIPSEA-protected.

    Following detailed quality evaluation and statistical analysis, de-identified aggregated equipment failure information is shared with all stakeholders, including BSEE, via published annual reports and public data dashboards.

  • For equipment failure reports required by BSEE's Well Control Equipment Rule, why use SafeOCS for data collection rather than the Blowout Preventer (BOP) Reliability Joint Industry Project (JIP)?

    The International Association of Drilling Contractors (IADC) and the International Association of Oil and Gas Producers (IOGP) established the BOP Reliability JIP in early 2016 to improve the safety and reliability of subsea BOPs and to standardize BOP failure reporting. The WCE Failure reporting component of SafeOCS captures data required by BSEE regulations and is consistent with what is captured by the JIP. The objective of SafeOCS is to capture and analyze data from all companies, not just those who are participants in the JIP.

  • Why the change from WCR to WCE in the program title?

    SafeOCS revised the program area title from Well Control Rule (WCR) to Well Control Equipment (WCE) failure reporting to more accurately reflect the scope of the data collection, which includes failures of well control equipment systems under 30 C.F.R. § 250.730(c) of the rule.

    The full Well Control Rule encompasses various provisions for well control and blowout preventer systems in addition to equipment failure reporting.

    Most references to the program area on the SafeOCS website have been revised to WCE; however, some previously published documents and existing images may retain the WCR title.

Back to General FAQs

SPPE FAQs

  • What equipment does BSEE consider SPPE?

    Per 30 CFR § 250.801, BSEE considers the following equipment to be types of SPPE:

    • Surface safety valves (SSV) and actuators;
    • Boarding shutdown valves (BSDV) and actuators;
    • Underwater safety valves (USV) and actulators;
    • Subsurface safety valves (SSSV) and associated safety valve locks and landing nipples; and
    • Gas lift shutdown valves (GLSDV) and their actuators associated with subsea systems.
  • Who must submit a report?

    BSEE requires all oil and gas operators on the OCS to report failures of safety and pollution prevention equipment (SPPE) under 30 CFR § 250.803 of BSEE's Production Safety Systems Rule. Under the rule, operators must submit SPPE failure reports directly to BTS as BSEE’s designee under the regulations for collecting SPPE failure data and reports.

    Operators must also follow the failure reporting requirements contained in the following ANSI/API Standards (all incorporated by reference in 30 CFR § 250.198):

    • SSVs, BSDVs, GLSDVs and USVs - ANSI/API Spec. 6A, section 10.20.7.4
    • SCSSVs and SSCSVs - ANSI/API Spec. 14A, section 7.10 and ANSI/API RP 14B, Annex F
  • What must be reported?

    All failures of safety and pollution prevention equipment (SPPE) must be reported. An equipment failure is any condition that prevents the equipment from meeting the functional specification or purpose.

  • When should a report be submitted?

    A written notice of equipment failure must be provided within 30 days after discovering and identifying the failure. An investigation and a failure analysis must also be performed within 120 days of the failure to determine the cause of the failure.

  • How should reports be submitted?

    Please follow the link below to log in and submit a report:

    • Navigate to the SPPE data submission portal here.
    • Select the notification form type.
    • Complete the notification.

    All reports and follow-up investigations should be submitted to BTS using this link.

  • What additional protections are offered by submitting equipment failure reports to BTS rather than directly to BSEE?

    BTS operates the SafeOCS reporting system. All reports submitted to BTS for inclusion in SafeOCS are accessible only by BTS authorized personnel and BTS-designated agents under CIPSEA. BSEE does not have access to reports you submit to BTS.

    As an independent federal statistical agency, BTS has the authority and obligation under CIPSEA and the agency's authorizing statute to protect the confidentiality of your data, including but not limited to company information, personally identifiable information, and sensitive or proprietary information. By submitting to BTS, your data are protected from release to the public, BSEE, and other non-CIPSEA federal agencies. Data are also protected from subpoenas and Freedom of Information Act requests.

    In contrast, equipment failure reports submitted directly to BSEE do not receive CIPSEA protections and could be subject to release under the FOIA or other authority.

  • What information is shared with BSEE?

    When you submit a notice of equipment failure to SafeOCS, BTS sends an automated email to BSEE with only the following information: date, company name, company ID (if available), and event reference number. Click here for an example email notification to BSEE.

    BTS shares this information with BSEE to demonstrate that operators are complying with the regulation without sharing the details of the reports, which are CIPSEA-protected.

    Following detailed quality evaluation and statistical analysis, de-identified aggregated equipment failure information is shared with all stakeholders, including BSEE, via published annual reports and public data dashboards.

  • BSEE published a Final Rule on September 28, 2018, that revised the 2016 Production Safety Systems Rule (81 FR 61834). This rule became effective on December 27, 2018. How did this impact the SafeOCS SPPE data collection program?

    The rule clarified that gas lift shut down valves (GLSDVs) are considered safety and pollution prevention equipment (SPPE). The rule also clarified failure reporting requirements, including allowing BSEE to direct operators to submit failure reports to a third party, acting on behalf of BSEE. BSEE subsequently designated the Bureau of Transportation Statistics for collection of equipment failure information allowing it to be protected from release under the Confidential Information Protection and Statistical Efficiency Act (CIPSEA).

Back to General FAQs

ISD FAQs

  • What is the objective of ISD?

    The overarching objective of the SafeOCS ISD program is to establish a comprehensive source of near miss and safety event reports from the offshore energy industry.

  • How do I join SafeOCS ISD?

    Once a company decides to voluntarily submit its safety data to BTS, the first step is for that company to meet with BTS to discuss the elements of a Memorandum of Agreement (MOA). You can find a draft template here. The MOA, which is specific to each company, details the scope of the engagement between the company and BTS, including the following:

    • the type of data to be submitted (e.g., reportable incidents, near misses, etc.)
    • the event date ranges of submitted data
    • the format of the data to be provided to BTS
    • the company’s expectations regarding data review and analysis
  • Why has ISD reporting been initiated?

    The SafeOCS ISD program was initiated to address concerns raised in various industry reports regarding the capture and sharing of key learnings from significant events, including near misses and stop work events. The ISD conceptual framework was developed collaboratively with the industry and aims to overcome information-sharing obstacles for a broad range of data to aid the industry in improving safety performance. You can find more information about this collaboration and a joint value proposition here.

  • Why should I participate in the SafeOCS ISD program?

    By participating in the ISD program, you contribute to the combined knowledge for making the OCS a safer place to work and operate. In addition, participants can incorporate the learnings from shared incident and event data into their continuous improvement efforts. This is particularly important for major hazards and associated prevention/mitigation barriers.

    Key benefits of this effort include the following:

    • provides a secure, central repository for collecting, collaborating, and sharing learnings of safety-related data
    • identifies types of data that provide valuable learning information
    • aligns incident and indicator definitions
    • implements a robust methodology for identifying systemic issues
    • disseminates results to stakeholders who can then take actions to reduce or eliminate the risk of reoccurrence through greater barrier integrity
    • provides opportunities to network and benchmark performance
    • sets up a framework wherein actions cannot legally be taken against data submitters, nor can raw data be used for regulatory development purposes

    In addition to analysis of industry-wide patterns, BTS is available to conduct separate analyses on data specific to your company.

  • Why not limit the scope of the ISD program to what BSEE already collects through incident reporting requirements?

    While there is certainly value in further analyzing the regulatory-required incident and spill event data currently submitted to BSEE under 30 C.F.R. § 250.188 and 254.46, the opportunities for deriving learnings from these data are limited to the data fields mandated by BSEE. In addition, when you consider the historic safety triangle, familiar to so many in the industry, the largest number of safety events, including potentially significant near misses, safety observations, and stop work events, are not required by regulation to be reported. Therefore, the industry must gain a better understanding of those non-reportable safety events.

    The ISD program includes both voluntarily submitted safety event data and data required to be reported to BSEE. The regulatory-required data is provided to SafeOCS by participating companies and by BSEE.

  • Who can participate in ISD reporting?

    All operators, drilling companies, and service provider companies working on the OCS are invited to join the SafeOCS ISD program.

  • How should reports be submitted?

    Participating companies may submit reports individually through a block transfer of multiple reports or a database transfer. Your company will work with BTS to determine a method for transfer to allow for data submission. Your company's MOA with BTS will describe how you will provide ISD reports.

    SafeOCS developed the SafeOCS ISD User Guide to assist in the data submission process.

    You can find the link for submitting ISD reports here.

  • What are the expectations for participation?

    Participating companies are expected to submit data on a monthly or quarterly basis. In addition to submitting data, companies participating in ISD may nominate representatives for ad hoc work groups, described above.

  • My company has domestic and/or international activities in other areas in addition to the Gulf of Mexico. Is the data I submit to SafeOCS ISD limited to only the Gulf of Mexico?

    No. Companies are free to send safety data about other regions to SafeOCS. While the current focus is primarily on the Gulf of Mexico, we hope to expand the scope beyond this region so that the industry can better generate and leverage safety learnings from all regions.

  • What data confidentiality protections are in place for ISD?

    As an independent federal statistical agency, BTS has the authority and obligation under CIPSEA and the agency's authorizing statute to protect the confidentiality of your data, including but not limited to company information, personally identifiable information, and sensitive or proprietary information. By submitting to BTS, your data are protected from release to the public and other non-CIPSEA federal agencies. Data are also protected from subpoenas and Freedom of Information Act requests.

Back to General FAQs
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