Reporting to SafeOCS
In August 2013, the Bureau of Safety and Environmental Enforcement (BSEE) and BTS signed an interagency agreement to develop and implement SafeOCS, a voluntary program for confidential reporting of “near misses” occurring in the OCS. This program serves as a resource to help industry capture and share key lessons from significant near-miss and other safety events, with the objective of preventing, identifying, and mitigating potential high-consequence risks. On September 7, 2016, BSEE published a Production Safety Systems Rule (PSSR) substantially revising 30 CFR part 250, subpart H (2016 PSSR) (81 FR 61834). That final rule addressed issues such as production safety systems, subsurface safety devices, and safety device testing, including safety and pollution prevention equipment (SPPE). These systems play a critical role in protecting workers and the environment. Most of the provisions of that rulemaking took effect on November 7, 2016. In August 2016, BSEE and the BTS entered into a Memorandum of Understanding (MOU) to allow BTS to collect equipment failure data and other safety reports required under BSEE rules for safety and pollution prevention equipment (SPPE). On October 26, 2016, the BSEE director announced the expansion of the SafeOCS program beyond near miss reporting to include the confidential collection of equipment failure data pursuant to regulations 30 C.F.R.§ 250.803. In September 2018, BSEE published revisions to the 2016 Production Safety Systems Rule (PSSR), which clarifies provisions for SPPE failure reporting. More specifically, pursuant to 30 CFR § 250.803, effective December 27, 2018, operators must report the following:
*Currently, the designee of the Chief of OORP is the U.S. Department of Transportation’s Bureau of Transportation Statistics (BTS). Operators submit this information through www.SafeOCS.gov, where it is received and processed by BTS. Reports submitted through www.SafeOCS.gov are collected and analyzed by BTS and protected from release under the Confidential Information Protection and Statistical Efficiency ACT(CIPSEA) (44 U.S.C.101) |
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- Who must submit a
report?
All oil and gas operators on the OCS are required by BSEE to report failures of safety and pollution prevention equipment (SPPE) under 30 C.F.R. § 250.803 of BSEE's Production Safety Systems Rule. Operators are required to submit SPPE failure reports directly to BTS as BSEE's designee under the regulations for the collection of SPPE failure data and reports. All operators must follow the failure reporting requirements contained in the following ANSI/API Standards:
- • ANSI/API Spec. 6A, section 10.20.7.4: for SSVs, BSDVs, GLSDVs and USVs
- • ANSI/API Spec. 14A, section 7.10: for SSSVs
- • ANSI/API RP 14B, Annex F: for SSSVs
- • (all incorporated by reference in §250.198)
Within 30 days after the discovery and identification of the failure, operators must provide a written notice of equipment failure to the manufacturer of such equipment and to BTS as BSEE’s designated a third party.
- What additional
protections are offered by submitting equipment failure
reports to BTS rather than directly to BSEE?
The SafeOCS reporting system is operated by BTS. BSEE does not have access to reports that are submitted to BTS.
Any reports submitted to BTS for inclusion in SafeOCS are accessible only by BTS authorized personnel and BTS-designated agents under CIPSEA. As an independent federal statistical agency, BTS has the authority and obligation under CIPSEA and the agency's authorizing statute to protect the confidentiality of your data, including but not limited to company information, personally identifiable information, and sensitive or proprietary information. By submitting to BTS, your data are protected from release to the public, BSEE, and other non-CIPSEA federal agencies. Data are also protected from subpoenas and Freedom of Information Act (FOIA) requests.
In contrast, equipment failure reports submitted directly to BSEE do not enjoy CIPSEA protections, and could be subject to release under the FOIA or other authority.
- What must be
reported?
All failures of safety and pollution prevention equipment (SPPE) must be reported. An equipment failure is any condition that prevents the equipment from meeting the functional specification or purpose.
- When should a
report be submitted?
A written notice of equipment failure must be provided within 30 days after the discovery and identification of the failure. An investigation and a failure analysis must also be performed within 120 days of the failure to determine the cause of the failure.
- How should
reports be submitted?
Please follow the link below to submit a report:
• Safety and Pollution Prevention Equipment
It links to a separate page that will request event, equipment, lease/company, and other information. All reports and follow-up investigations should be submitted to BTS.
- BSEE published a
Final Rule on September 28, 2018 that revises the 2016
Production Safety Systems Rule (PSSR) (81 FR 61834). This
rule becomes effective on December 27, 2018. What
provisions were revised?
BSEE carefully analyzed all 484 provisions in the original 2016 Production Safety Systems Rule and determined that 84 of those provisions – less than 18 percent of the original rule – were appropriate for revision or deletion. The final rule also adds seven new provisions.
The Final Rule includes, but is not limited to, the following revisions:
-
• Update the incorporated
edition of standards referenced in subpart H.
The revised rule incorporates 12 updated industry standards. -
• Revise requirements for
SPPE to clarify the existing regulations, and remove the
requirement for operators to certify through an
independent third party that each device is designed to
function in the most extreme conditions to which it will
be exposed and that the device will function as designed.
Compliance with the various required standards (including American Petroleum Institute (API) Spec Q1, American National Standards Institute (ANSI)/API Spec. 14A, ANSI/API RP 14B, ANSI/API Spec. 6A, and API Spec. 6AV1) ensures that each device will function in the conditions for which it was designed. -
• Clarify that gas lift shut
down valves (GLSDVs) are considered safety and pollution
prevention equipment (SPPE).
GLSDVs already must meet the requirements in §§ 250.835 and 250.836 for boarding shutdown valves (BSDVs). -
• Clarify failure reporting
requirements.
Allows BSEE to direct operators to submit failure reports to a 3rd party, acting on behalf of BSEE. BSEE has a contract with the Bureau of Transportation Statistics (BTS) to collect and process failure reporting data, allowing the information that the operators submit to be protected from release under the Confidential Information Protection and Statistical Efficiency Act (CIPSEA). -
• Clarify and revise some of
production safety system design requirements.
Includes revising the requirements for piping schematics, simplifying the requirements for electrical system information, clarifying when operators must provide certain documents to BSEE, and clarifying when operators must update existing documents. -
• Clarify requirements for
atmospheric vessels carrying Class 1 liquids.
Requires the inclusion on design documents of atmospheric vessels containing Class 1 liquids that are connected to the process system. -
• Update requirements for
inspection of the fire tube for tube-type heaters.
Deletes the requirement that fire tubes be removed during inspections, as alternate inspection methods and technology have proven to be effective and as safe or safer than removing the tube for visual inspection. -
• Clarify the requirement
for notifying the District Manager before commencing
production.
Specifies that drawings do not need to be updated until a modification request is submitted to BSEE, but operators must receive approval from the district manager before commencing production through or utilizing the new or modified system.
-
• Update the incorporated
edition of standards referenced in subpart H.
BTS releases the 2017 Annual Report: Blowout Prevention System Safety
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:- The top four reporting operators represented 81.8 percent of reported component events and 32.7 percent of new wells spud in the Gulf of Mexico for 2017.
- There was a decrease in overall reporting from 2016 to 2017. The event reporting rate adjusted for rig activity (defined as events per 1,000 BOP days) decreased from 122.3 in 2016 to 59.8 in 2017.
- There was an increase in reporting equipment component failures while not in operation for rigs with subsea BOP stacks. The percent of subsea, not-in-operation notifications for 2017 was 86.4 as compared to 79.8 percent for 2016.
- There was a decrease in the rate of unplanned stack pulls for rigs with subsea BOP stacks. In 2016 the rate was 7.2 percent and in 2017 it was 5.6 percent.
- Based on follow-up documents submitted to SafeOCS, only 12 of the 18 components involved in unplanned stack pulls were sent to shore for further analysis by the original equipment manufacturer (OEM) or a third party, despite the expectation of a root cause failure analysis (RCFA) for every stack pull.
- Of 1,044 subsea events in 2017, one reported loss of containment of synthetic oil based mud (drilling fluid) during in-operation rig activity. No surface stack events resulted in loss of containment.
- Leaks remained the most frequently reported observed failure and wear and tear remained the most frequently reported root cause of failure events in 2017 as they were in 2016.
 SafeOCS@dot.gov |
 1-844-OCS-FRST
(1-844-627-3778) |
 SafeOCS, BTS-USDOT,
P.O. Box 23295, Washington, DC 20026-3295 |