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). A draft
template is posted as part of this web site. This Agreement, which
is unique and specific to that company, details the scope of
engagement between the company and BTS, including:
the type of data to be submitted (i.e., reportable incidents,
near misses, etc.),
the event date ranges (i.e., number of years) of submitted data,
the format of the database to be provided to BTS (i.e., use
existing data input form or a company-specific format), and
that company’s expectations regarding data review and analysis.
The MOA identifies the various sections and topics that will
- Executive Summary, with purpose and name of company
1. Description of parties who are part of the
2. Legal authorities
3. Background on the SafeOCS program
4. Overview of Confidential Information Protection &
Statistical Efficiency Act (CIPSEA)
5. Responsibilities and obligations of the parties to
7. Financial responsibilities
8. Dispute resolution process
9. Terms of agreement and right of termination
10.Signatory authority, modification, and relationship of parties
Data transfer protocol
Record layout and metadata
Non-disclosure agreement What Happens
1. Upon execution of the MOA, each company is then ready to
transmit data to BTS via a secure portal on the SafeOCS ISD
Safety data that is required by regulation to be submitted to
BSEE must still be reported directly to BSEE, however the SafeOCS
ISD offers industry an alternative to voluntarily report the data
directly to BTS, which would then subject the data to CIPSEA
There is no limit on how soon a report should be submitted from
the time an event happens, however companies are encouraged to
report it as soon as possible (i.e., suggest no less frequently
than quarterly). Timely reporting is crucial for assuring the
quality of the information and data collected about a safety
BTS will solely own and manage the source data in perpetuity.
2. BTS data analysts will review the data and aggregate
results for further review and analysis.
Part of the review is to identify reports that may be redundant
due to submittal from more than one source (e.g., company,
individual, BSEE, etc.).
Review will be conducted by BTS technical staff with expertise in
CIPSEA, data system development, data quality assurance, data
processing, data review teams, and data disclosure boards.
3. BTS will establish Data Review Teams (as needed) and
designate team members as Agents under CIPSEA.
Data Review Team members will be oil and gas industry subject
matter experts (SMEs) who will be charged with evaluating,
reviewing, and analyzing microdata for the purpose of identifying
reporting trends and producing industry-wide safety statistics.
Data Review Team will be composed of core members and specialized
SMEs who can be called upon as needed based on the technical
content of incoming reports.
on the characteristics of the aggregated data being reviewed,
participating companies may opt to nominate different SMEs for
the Data Review Team.
for Data Review Team members will be submitted to the SafeOCS
Program Manager for consideration and approval.
team member will receive CIPSEA training and be required to
execute a Non-Disclosure Agreement (NDA) required by CIPSEA.
While the intent will be to "blind" some of the data before the
Data Review Team members see it, there will still be an
expectation under CIPSEA that each member sign an NDA.
As part of the data review, Data Review Team members will focus
on the following tasks:
determine if data entries may sense,
evaluate the data submitter’s risk assessment and
root cause analysis (if any) for the incident,
evaluate whether review by another SME is
follow up with the data submitter (as required, and
only with BTS approval to release that information) if
supplemental data or other clarifications are required, and
assess the potential future significance of each
industry SMEs will assist BTS with the definition of the database
fields, internal analytical data fields, and updates to the data
collection forms, as well as contribute to the annual report
draft and review process.
work performed by Data Review Team members will take place in a
secure BTS data space.
4. BTS will also establish a Disclosure Review Board to
review reports and other data products produced by the Data Review
Team in accordance with CIPSEA disclosure requirements and
expected compliance with principles and practices of a statistic
will designate Disclosure Review Board members as agents under
on the technical content of the report, members of the Disclosure
Review Board will be selected from participating companies and
other Federal agencies.
5. The BTS Director or Deputy Director will review all
analyses and reports, and issue approval for publication.
6. While BTS’s direct involvement will end after the
aggregated trends report is published, the ISD may form a
committee to address the analysis findings.
committee will include representatives from industry, BSEE, and
academia to determine the most appropriate use of the findings,
products, and reports.
will act as the technical representative on statistical issues
and data quality issues.
and BSEE may also work with professional societies like SPE
(Society of Petroleum Engineers International) to organize
workshops for all stakeholders to review the aggregated data as a
group and discuss possible mitigation steps to address any
resulting, potential safety concerns.