Reporting to SafeOCS
The Industry Safety Data (ISD) program, a component of BTS’s SafeOCS data sharing framework, provides a trusted, proactive means for the oil and gas industry to report sensitive and proprietary safety information, and to identify early warnings of safety problems by uncovering hidden at-risk conditions not previously exposed from analysis of reportable accidents and incidents. Through comprehensive analysis by professional statisticians and industry subject matter experts, the program allows the identification of trends or patterns before safety is compromised and provides a tool for continuous improvement by focusing on fixing impediments to safety.
BTS formed a Phase I Planning Team consisting of representatives from companies working in the Gulf of Mexico who expressed interest in participating as early implementers for the suggested enhancements to the SafeOCS program. This team discussed the type of data that should be submitted to ensure that data captured has appropriate learning value. The scope of data discussed includes incidents, near misses, stop work events, and associated metadata for the period from 2014 through 2017. The aggregated data will be reviewed and analyzed, and the results will be shared with the public in a report to be released no later than January 2019.
All companies working in the OCS are invited to join Phase II of this program which will incorporate enhancements learned from the Phase I effort. Companies joining Phase II would submit data for safety events occurring after January 1, 2018. A related goal of the ISD is to provide a mechanism whereby participating companies can submit safety data in whatever format they currently use to minimize incremental effort on the company’s part.
One of the key benefits associated with submitting safety data directly to BTS for aggregation and review is that it addresses concerns related to protection of the data source information. SafeOCS, including the ISD, operates under a Federal law, the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), which requires that the program protect data submitter identity and treat reports confidentially. Information submitted under CIPSEA is also protected from release to other government agencies, Freedom of Information Act (FOIA) requests, and subpoena. Even regulatory agencies such as BSEE cannot have access to a submitter’s identity or report. In addition, the information from individual records cannot be used for enforcement purposes. CIPSEA is subject to strict criminal and civil penalties for noncompliance.
Once data are aggregated, BTS will analyze safety data reports submitted by companies involved in OCS activities. BTS will also work with subject matter experts to further analyze these reports to identify potential causal factors and trends. The results of these aggregated analyses will be distributed by BTS through public reports. Industry workshops will then be scheduled to allow operators, service companies, drilling contractors, regulators, and other stakeholders to discuss the results and share learnings.
The ISD program provides a trusted, proactive means for the oil and gas industry to report sensitive and proprietary safety data: safety events, near misses, stop work events, and other safety-related data. Professional statisticians and industry experts perform comprehensive analysis to identify safety trends and enable continuous safety improvement.
Additional background information on the ISD program can be found here.
BSEE initiated the ISD reporting component of SafeOCS to address concerns raised in a variety of industry reports regarding the industry's inability to capture and share key learnings from significant events, including near misses and stop work events. The ISD conceptual framework was developed collaboratively with industry, and aims to overcome information-sharing obstacles for a broad range of data to aid industry in improving safety performance. More information about this collaboration and a joint value proposition can be found here.
In addition, BSEE initiated ISD reporting for the following reasons:
By participating in the ISD program, you are contributing to the combined knowledge on how make the OCS a safer place to work and operate. 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:
In addition to analysis of industry-wide patterns, BTS is available to conduct separate analyses on data specific to your company.
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. 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 and stop work events, are not required by regulation to be reported. Therefore, it is imperative for industry to gain a better understanding of those non-reportable safety events.
The ISD program includes both voluntarily submitted safety event data as well as data required to be reported to BSEE. The regulatory-required data is provided to SafeOCS by participating companies and by BSEE.
Phase I of ISD reporting is a collaborative effort among BTS and representatives from nine (9) companies working in the Gulf of Mexico who expressed an interest in participating as early implementers. The scope of Phase I data includes safety events, near misses, stop work events, and associated metadata for the period from 2014 through 2017. A report containing analyses of the aggregated data is expected to be shared with the public no later than January 2019.
Phase II of ISD reporting will incorporate enhancements learned from the Phase I effort. Companies joining Phase II would submit data for safety events occurring after January 1, 2018.
The industry participants on the Phase I Planning Team identified the core data fields based on what the group felt offered the most learning value for industry in managing and mitigating safety risks. These core data fields will also apply to Phase II in the first year. After that, the Planning Team will review the need to add new data fields based on a review of aggregated data. The current core data fields are expected to remain in place unless the Planning Team identifies a compelling reason to change them.
All operators, drilling companies, and service provider companies working on the OCS are invited to join Phase II.
Your company will need to contact BTS at 1-844-OCS-FRST (1-844-627-3778), or Demetra Collia at Demetra.firstname.lastname@example.org and sign a cooperative agreement with BTS to participate in ISD reporting. A cooperative agreement template can be found here.
Additional information about how to sign up to participate can be found here.
Reports may be submitted individually, through a block transfer of multiple reports, or through a database transfer. Your company will work with BTS to determine a method for transfer, with the goal of allowing for submission of data in whatever format you currently use to minimize incremental effort on your company’s part. Your company’s Cooperative Agreement with BTS will describe how you will provide ISD reports.
The SafeOCS ISD User Guide has been developed to assist in the data submission process.
The link for submitting ISD reports can be found here.
In addition to submitting data, companies participating in ISD may nominate representatives to participate on Data Review Teams to provide specialized expertise based on the technical content of incoming reports. Data Review Team members must be approved by the BTS SafeOCS Program Manager, undergo CIPSEA training, and sign a nondisclosure agreement. A nondisclosure agreement template can be found here.
To ensure reports do not inadvertently release identifiable information, a Disclosure Review Board reviews them prior to release to the public. The Disclosure Review Board may include representatives from participating companies.
Following the publication of a report, a committee may be formed to address the findings. Representatives from participating companies would be invited to serve on the committee.
Additional information about company participation can be found here.
No. Companies are free to send safety data about other regions to SafeOCS. While the current focus is primarily the Gulf of Mexico, we hope to expand the scope beyond this region so that industry can better generate and leverage safety learnings from all regions.
The Phase I Planning Team consists of representatives of those companies who have agreed to be early implementers of the program. This team is made up of operator, drilling company, and service provider company representatives. For Phase II, all participating companies will be invited to be members of the Planning Team, if interested. Depending on the response, BTS may opt to limit the size of the Planning Team to ensure its effectiveness, and steps may be taken at some point to rotate participants on the team to allow more companies to be part of this effort.
While the Planning Team in intended to be representative of the offshore oil and gas industry, the team functions as an extension of BTS. As such, and given that BTS is an independent Federal statistical agency, BTS will maintain a leadership role on the team throughout the process.
Members of the Planning Team may also opt to participate on one or more Data Review Teams, as appropriate, or suggest alternative representatives from their respective companies to be Data Review Team members depending on their area of expertise. As noted previously, all Data Review Team participants will be required to execute a Non-Disclosure Agreement with BTS.
General responsibilities for the Planning Team include the following:
The U.S. Department of Transportation’s Bureau of Transportation Statistics (BTS) has released the 2017 Annual Report: Blowout Prevention System Safety, which provides information on equipment component failures occurring during drilling and non-drilling operations on rigs in the Gulf of Mexico (GOM) Outer Continental Shelf (OCS). The reporting of such events is mandated by the Well Control Rule (WCR), published by the Bureau of Safety and Environmental Enforcement (BSEE), Department of the Interior. The publication of this report represents a groundbreaking collaboration between industry and government stakeholders and is a significant milestone in promoting safety on the OCS. The report includes an analysis of equipment component failures and other key information such as root causes of failure events, follow-up response to failures, and opportunities to improve data quality. In 2017, the first full year of mandated WCR reporting, 18 of 25 operators in the Gulf of Mexico reported 1,129 rig equipment component failure events, and the notifications involved 45 of 59 rigs operating in the Gulf of Mexico. The 18 reporting operators represent 90.2 percent of new wells drilled in the Gulf of Mexico. The report begins by analyzing aggregate equipment component failure data and then, in separate sections, presents statistics on the reported events for the two major types of BOP stacks (subsea and surface). Both types of BOP stacks were associated with component failures and most notifications were associated with the more complex subsea BOP stack (92.5 percent).Key findings:
BSEE is sponsoring four events on the voluntary SafeOCS Industry Safety Data program to facilitate further dialogue with the industry and encourage participation in the program.
General plenary sessions will be offered, and interested parties can schedule one-on-one sessions with the SafeOCS team. The plenary sessions are intended to provide attendees with the opportunity to give feedback and ask questions. Your feedback and questions will help us to expand the FAQs about the SafeOCS and improve the overall understanding of the voluntary program.
Dates, locations and session times are listed below.
******************************************************First Event: Learn from BSEE about SafeOCS (Open Plenary)
BSEE representatives will provide an overview of SafeOCS, including the program’s origins, goals, scope, and methods. Attendees will hear from BSEE on SafeOCS progress to date, ongoing efforts, and near-term plans for the program. BSEE will explain how companies can participate in the Phase II of the voluntary Industry Safety Data (ISD) program.
The July 16th meeting will be followed by three day-long events in three different locations to have in-depth discussions with BTS technical staff about the SafeOCS data system. Each day will include an optional abridged version of the July 16th meeting, followed by one-on-one sessions. BTS staff will meet with your company to discuss the SafeOCS ISD program and explore specifics about how to join Phase II. If you have any questions about the SafeOCS program and why your company should participate, these sessions are for you!
WASHINGTON - The U.S. Department of Transportation's Bureau of
Transportation Statistics (BTS) and the U.S. Department of the
Interior's Bureau of Safety and Environmental Enforcement
(BSEE) today announced the expansion of reporting of 'near
misses' on the Outer Continental Shelf (OCS) through the SafeOCS
program to now include the confidential collection of
equipment failure data in an effort to further reduce the risk
of offshore incidents.
Effective immediately, the offshore oil and gas industry will have the option to submit equipment failure reports for well control equipment, required under the Well Control Rule (30 CFR 250.730(c)), directly through SafeOCS. Effective Nov.7, industry will be required to submit reports for pollution prevention equipment, required under the Production Safety Systems Rule (30 CFR 250.803), through SafeOCS as the Chief's designee. All reports submitted through SafeOCS are collected and analyzed by BTS and are protected from release under the Confidential Information Protection and Statistical Efficiency Act (CIPSEA).
"We are encouraging industry to quickly begin taking advantage of the SafeOCS expansion," said BSEE Director Brian Salerno. "Shared awareness of safety trends better equips us all to quickly focus on emerging issues and thereby drive down the risk of serious incidents."
In August 2013, BSEE and BTS signed an interagency agreement to develop and implement SafeOCS, as a voluntary program for confidential reporting of 'near misses' occurring on the Outer Continental Shelf (OCS). Today’s expansion enables the SafeOCS system to be used to submit these required regulatory reports.
For notification forms, guidance, and additional information - or to submit reports, go to www.safeocs.gov.