Introduction
In the aftermath of the Deepwater Horizon oil spill, the oil and gas industry, regulators, and other stakeholders recognized the need for increased collaboration and data sharing to augment their ability to better identify safety risks and address them before an accident occurs. The SafeOCS program is one such collaboration between industry and government. It is a voluntary confidential reporting program that collects and analyzes data to advance safety in oil and gas operations on the Outer Continental Shelf (OCS). The US Bureau of Safety and Environmental Enforcement (BSEE) established the program with input from industry and then entered into an agreement with the US Bureau of Transportation Statistics (BTS) to develop, implement, and operate the program. As a principal statistical agency, BTS has considerable data-collection-and-analysis expertise with near-miss reporting systems for other industries and the statutory authority to protect the confidentiality of the reported information and the reporter’s identify. Source data submitted to BTS are not subject to subpoena, legal discovery, or Freedom of Information Act (FOIA) requests.
Solving for the Gap
Across industries, companies have long realized the benefits of collecting and analyzing data around safety and environmental events to identify risks and take actions to prevent reoccurrence. These activities are aided by industry associations that collect and share event information and develop recommended practices to improve performance. In high-reliability industries such as aviation and nuclear, it is common practice to report and share events among companies and for the regulators to identify hidden trends and create or update existing recommended practices, regulations, or other controls.
The challenge for the offshore oil and gas industry is that industry associations and the regulator are typically limited to collecting data on agency-reportable incidents. With this limitation, other high-learning-value events or observed conditions could go unnoticed as a trend until a major event occurs. This lack of timely data represented an opportunity for the industry and the offshore regulator (BSEE) to collaborate on a means of gathering safety-event data that would allow for analysis and identification of trends, thereby enabling appropriate interventions to prevent major incidents and foster continuous improvement. The SafeOCS Industry Safety Data (ISD) program provides an effective process for capturing these trends by looking across a wider spectrum of events, including those with no consequences.
Data Protection and Confidentiality
SafeOCS operates under a federal law, the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), which requires the program to protect any identifying, sensitive, or proprietary information it collects and prohibits its release to unauthorized persons or organizations. Information submitted under CIPSEA can be used only for statistical purposes.
Among the protections offered by CIPSEA, neither a government agency nor the courts may require, for any reason, a copy of a respondent’s report. Reports are also immune to the legal process and are exempt from FOIA requests. CIPSEA-protected data may not be disclosed in identifiable form for any non-statistical purpose without the informed consent of a respondent and cannot be used for enforcement or regulatory purposes.
Anyone working on a SafeOCS data-collection-and-analysis effort is subject to a nondisclosure agreement (NDA) as mandated by CIPSEA. Willful disclosure of confidential information by federal employees, agents, and contractors is subject to strict criminal and civil penalties.
Laying the Groundwork: SPE/BSEE Summit
From 2014 to 2016, BSEE and SPE worked with a team of industry representatives, as well as BTS, aviation, and shipping experts, to identify potential best practices for the capture and sharing of key learnings from safety and environmental events that were not currently being captured industrywide. The collaboration culminated in April 2016 when BSEE and SPE co-sponsored a summit that included representatives internal and external to the oil and gas industry to discuss what it would take to develop an industrywide safety data management database.
Although the scope of the summit initially focused on near misses, participants expanded the scope to include a broader range of safety data with learning value. The summit also clearly framed an additional goal of avoiding creation of another layer of reporting expectations beyond the requirements currently held by regulators and industry associations. The Summit Technical Report included an action item to create and pilot a process and database for aggregating and analyzing industry safety data as part of a centralized framework.
Initiating ISD Phase I—The Pilot
Following issuance of the SPE Technical Report, BTS formed a team of nine companies interested in participating in ISD phase I as early implementers and to assist BTS in designing the safety data management framework. The overriding objective for this pilot was to provide a proof of concept with a mix of operators, service, and drilling contractors representing a cross section of companies operating in the Gulf of Mexico.
As BTS had already been designated as the repository to collect and analyze mandatory Well Control Rule and Safety and Pollution Prevention Equipment (SPPE) data submitted by companies working in the OCS, it was the logical choice to collect and analyze safety data submitted voluntarily by companies participating in the ISD pilot program.
In January 2018, BTS formed the phase I planning team with subject-matter experts (SMEs) from each participating company with the objective of developing a proof of concept for a proposed industrywide safety-event database. All involved recognized the importance of industry input to maximize benefits of the end products.
Since such an effort had not been previously undertaken, it was important to set realistic and achievable goals for phase I. One challenge was the need to develop a process that overcame the challenges of collecting and aggregating safety data from disparate company-specific databases without requiring those companies to reformat their data, and then to recommend ways the industry might utilize and benefit from SafeOCS ISD reports.
BTS and the planning team members met several times over the next 18 months to review and discuss the aggregated data and brainstorm possible program enhancements. They also addressed how best to characterize the aggregated data to optimize sharing and learning opportunities for the industry. Results from the phase I effort, including key learnings, are detailed in a report on the BTS website.
SafeOCS ISD Process Overview—Moving Beyond Phase I
The ISD phase I effort resulted in development of a process for data collection, analysis, and dissemination (Fig. 1).
ISD participants must first execute a Memorandum of Agreement (MOA) with BTS when they decide to participate. The MOA addresses the scope, format, and frequency of data to be submitted. Upon signing the MOA, each company then uploads its data to BTS via a secure online portal that ensures the data files are subject to the confidentiality protections of CIPSEA.
Next, BTS staff, with assistance from independent industry SMEs, processes and prepares the data for further review and analysis. BTS translates all submitted data to a standardized template with the core data fields in SafeOCS to allow for effective and meaningful aggregation and analysis. This review includes identification of multiple reports for the same event submitted from more than one source (e.g., operator, service provider, drilling contractor, or construction contractor). These reports are then consolidated into a more comprehensive event record. To address instances where many of the pertinent event details are included as part of the event description, BTS is developing machine-learning tools to assist with the record review.
After the initial data preparation, BTS analysts conduct exploratory data analysis to ensure data quality. Assisted by independent industry SMEs, BTS conducts analyses of the aggregated data to identify trends and high-value learnings.
SafeOCS Reports
As part of the review process, as appropriate, BTS establishes a data review team representing participating companies, BTS staff, and independent SMEs to assist with assessing, reviewing, and analyzing data. Each team member is required to receive confidentiality training and sign an NDA, and then is designated an agent under CIPSEA. Unlike the independent industry SMEs who assist BTS staff in reviewing detailed event records as submitted, industry SMEs assess and analyze only aggregated data. Companies can always access and analyze their own data.
A key outcome of the SafeOCS ISD program will be the use of an interactive dashboard on the SafeOCS website. This dashboard, expected to become available in early 2021, will allow companies to view their own data online and compare them against aggregated industry results. The dashboard will also provide the capability of analyzing data using a variety of primary and secondary sort criteria. Fig. 2 is an example of the proposed dashboard’s functionality.
Scope of Data
A key desire among industry participants during the development of the database was to ensure that any safety data captured are considered value-added and enhance the industry’s ability to learn from safety events and mitigate future occurrences. Fig. 3 is a summary of core data that are currently part of the program.
Safety Data Analysis Structure
Aggregated data are grouped into three focus areas: process safety, personal safety, and environmental stewardship.
Process safety hazards generally involve the potential release of harmful substances arising from operation of a drilling rig or production platform (e.g., well or production operations). These hazards, which include low-frequency, high-consequence events, can have the potential for serious consequences such as loss of the facility, fatalities, damage to the environment, or harm to the company’s reputation and financial health. The International Association of Oil & Gas Producers (IOGP) Report 456 is used as the basis for defining these events.
Personal safety hazards involve the potential for harm to personnel due to injury or illness. Many companies employ mature data-collection processes for personal safety incidents at all levels of the safety triangle. As with process safety, there may be learnings from personal safety events that are often viewed as less significant but have the potential to result in injury.
Environmental stewardship hazards have the potential to harm ecosystems by polluting waters, killing wildlife, and/or contaminating habitats. Given the sensitivity of the environment where offshore activities occur, SafeOCS seeks to capture events involving environmental hazards to help develop and/or improve appropriate controls.
This analytical structure is intended to present results in a way that industry and other stakeholders can advance safety and environmental protection. Increased industry participation in SafeOCS will further enhance the program’s ability to highlight potential problem areas and best practices that could apply more broadly. The analytical results can also be used to support the identification and development of appropriate controls such as training, operating procedures and practices, or competency assessments.
Next Steps
As the SafeOCS ISD program progresses, it will be important to consider the following enhancements to both the program itself and the company-specific data submissions to facilitate data mapping and enhance data analysis.
- Companies are encouraged to submit additional information about unsafe actions or conditions (e.g., safety observations) that may be precursors to events if circumstances at the time of the event had been different.
- BTS may consider expanding the use of drop-down menus to harmonize entries and address the challenges encountered around data-field inconsistencies and misspellings.
- Given that a key premise of SafeOCS ISD is to capture more data than is currently required by regulation, all participants are encouraged to provide data related to safety events that may occur while off-shift or when the property damage falls below the reporting threshold.
- All companies are encouraged to consider the potential injury consequences of dropped objects based on existing industry-recognized practices.
- Participants are encouraged to provide more information about causal factors and/or more detailed text descriptions of the event. To the extent practicable, companies submitting data should also provide additional event details (such as incident investigation reports, photos, etc.) as this will allow for more meaningful analyses.
- BTS is working with the Center for Offshore Safety and the Offshore Operators Committee on how best to integrate the aggregated industry trends with the work of their ongoing technical subcommittees and to use the knowledge gained through this program to develop new or modified risk controls and support systems such as training or awareness programs.
- Industry workshops should be held, as warranted, to network, share lessons learned, review aggregated results, discuss causal factors, and discuss potential actions to prevent reoccurrence and thereby improve safety.
- BTS is continuing discussions with industry stakeholders, including operators, drilling contractors, service companies, original equipment manufacturers, and BSEE, to ensure the SafeOCS ISD program provides value to stakeholders.
- BTS will proceed with plans to cross-link the SafeOCS ISD database with the databases of the other SafeOCS components (i.e., equipment-failure reporting, SPPE-failure reporting), as well as other data sources, to provide more complete event details and evaluate potential correlations.
For Further Reading
Assessing the Processes, Tools, and Value of Sharing and Learning from Offshore E&P Safety-Related Data. SPE Technical Report. September 2016.
Collia, D. and Moreau, R. 2019. SafeOCS Industry Safety Data: The Value Proposition for the Oil and Gas Industry. Mary Kay O’Connor Process Safety Center International Symposium. October 2019.
Process Safety—Recommended Practice on Key Performance Indicators. IOGP Report 456. November 2018.
Arscott, L. and Moreau, R. 2020. Post-Macondo Focus on Safety. J Pet Technol.
Demetra Collia is office director in the Office of Safety Data and Analysis, Bureau of Transportation Statistics in the US Department of Transportation. She has 38 years of experience in the areas of occupational health and safety, public health, and transportation safety. She spent 10 years developing health standards for the US Occupational Safety and Health Administration addressing occupational risk to chronic and infectious disease such as cancer, tuberculosis, and hepatitis B. For the past 17 years, she has developed and managed three near-miss reporting safety programs, including the SafeOCS program. She holds a BA in chemistry and mathematics from Hope College, an MA in statistics from Western Michigan University, and an MHS in biostatistics and epidemiology from Johns Hopkins.
Roland Moreau retired from ExxonMobil in 2014 with 34 years of service during which he held the position of safety, security, health, and environmental manager for several ExxonMobil business units. He was the 2018 president of the American Institute of Mining, Metallurgical, and Petroleum Engineers (AIME) and serves as a trustee on the United Engineering Foundation Board, served two terms on the SPE Board of Directors, first as Technical Director of HSSE-SR and later as vice president of finance. Moreau co-chaired the April 2016 Summit with BSEE referenced herein, and he is currently consulting with BTS on the development of the industrywide safety data management framework. He holds a BSME from Worcester Polytechnic Institute and an MBA from Fairleigh Dickinson University.