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 be addressed:

1. -   Executive Summary, with purpose and name of company
2. 1.   Description of parties who are part of the Agreement
3. 2.   Legal authorities
4. 3.   Background on the SafeOCS program
5. 4.   Overview of Confidential Information Protection & Statistical Efficiency Act (CIPSEA)
6. 5.   Responsibilities and obligations of the parties to the Agreement
7. 6.   Communications
8. 7.   Financial responsibilities
9. 8.   Dispute resolution process
10. 9.   Terms of agreement and right of termination
11. 10.Signatory authority, modification, and relationship of parties

          Appendices:
          A.  Data transfer protocol
          B.  Record layout and metadata
          C.  Non-disclosure agreement

What Happens Next?

1. Upon execution of the MOA, each company is then ready to transmit data to BTS via a secure portal on the SafeOCS ISD website: www.safeocs.gov.

• 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 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 (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 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.
• 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.
• Independent 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.
• 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. 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.

• 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.