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:
type of data to be submitted (i.e., reportable incidents, near
event date ranges (i.e., number of years) of submitted data,
format of the database to be provided to BTS (i.e., use existing
data input form or a company-specific format), and
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. Description
of parties who are part of the Agreement,
- 2. Stated
purpose of the Agreement,
- 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. Background
on the SafeOCS program,
- 5. Description
of the scope of the BTS SafeOCS reporting program as determined
by the data submitting company,
- 6. Detail
on how SafeOCS data will be used,
of the parties to the Agreement,
- 8. Points
- 9. Agreement
dispute resolution process,
- 10. Grounds
for termination of the Agreement,
Description of company-specific data transfer protocol,
Record layout and metadata, What Happens
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.
can either be submitted using the form already available in
SafeOCS, or a company can submit the data in its format.
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.
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
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.
of the review is to identify reports that may be redundant due to
submittal from more than one source (e.g., company, individual,
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.
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. BTS will work
with the various industry associations and professional societies
to obtain solid recommendations for team membership.
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.
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
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.
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. 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.
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.