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 Cooperative Agreement. 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.

While the specific details of each Cooperative Agreement will be unique to each company, the following list identifies the various sections and topics that will be addressed:

1. 1.  Description of parties who are part of the Agreement,
2. 2.  Stated purpose of the Agreement,
3. 3.  Overview of the federal regulatory citations that authorize the BTS Director to enter into such agreements for purposes of data collection and analysis,
4. 4.  Background on the SafeOCS program,
5. 5.  Description of the scope of the BTS SafeOCS reporting program as determined by the data submitting company,
6. 6.  Detail on how SafeOCS data will be used,
7. 7.  Responsibilities of the parties to the Agreement,
8. 8.  Points of contact,
9. 9.  Agreement dispute resolution process,
10. 10.  Grounds for termination of the Agreement,
11. 11.  Signatures.

          Attachments:
          I Description of company-specific data transfer protocol,
          II Record layout and metadata,

What Happens Next?

1. Upon execution of the Cooperative Agreement, each company is then ready to submit data directly to BTS for inclusion as part of the ISD data repository.

• Data can either be submitted using the form already available in SafeOCS, or a company can submit the data in its format.
• Safety data that is required by regulation to be submitted to BSEE may be still be reported directly to BSEE, however the SafeOCS ISD offers industry an alternative to report the data directly to BTS, which would then subject the data to CIPSEA protections.
• 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. Timely reporting is crucial for assuring the quality of the information and data collected about a safety event.
• 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.
• Each 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.
• Depending on the characteristics of the aggregated data being reviewed, participating companies may opt to nominate different SMEs for the Data Review Team.
• Nominations for Data Review Team members will be submitted to the SafeOCS Program Manager for consideration and approval. BTS will work with the various industry associations and professional societies to obtain solid recommendations for team membership.
• Each 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:
  
  • a.   determine if data entries may sense,
  • b.   evaluate the data submitter’s risk assessment and root cause analysis (if any) for the incident,
  • c.   evaluate whether review by another SME is warranted,
  • d.   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
  • e.   assess the potential future significance of each incident.
• Industry SMEs will assist BTS and BSEE 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.
• All 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 agency.

• BTS will designate Disclosure Review Board members as agents under CIPSEA.
• Depending on the technical content of the report, members of the Disclosure Review Board will be selected from participating companies and other Federal agencies.

5. Senior level review of documents prior to publication will be conducted by the Senior Review Board that may include representatives from key government agencies, wherein all members of this review board are designated as Agents under CIPSEA. The objective of these reviews will be to focus on oil and gas oversight and transportation policy issues with broader safety implications for the oil and gas industry.

6. The BTS Director or Deputy Director will review all analyses and reports, and issue approval for publication.

7. 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.

• This committee will include representatives from industry, BSEE, and academia to determine the most appropriate use of the findings, products, and reports.
• BTS will act as the technical representative on statistical issues and data quality issues.
• BTS 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.