Comment from Persistence Analytics Group LLC

Comment on DOT-OST-2026-1783 Oil and Gas Industry Safety Data Program Persistence Analytics Group LLC / United Grid submits this comment regarding the Bureau of Transportation Statistics renewal of the Oil and Gas Industry Safety Data Program. PAG / United Grid supports the continuation of a confidential, voluntary safety-data program for offshore oil and gas operations. The ability to identify near misses, unsafe conditions, causal factors, and accident precursors before they become fatalities or major incidents is essential to energy security, worker safety, infrastructure reliability, and public trust. The key issue is not only whether safety data are collected. The key issue is whether the program produces decision-grade evidence that helps operators, regulators, and other stakeholders identify where safety assumptions are failing before those failures become operational events. PAG / United Grid recommends that BTS continue the ISD program with emphasis on the following: 1. Early-warning value Near-miss and precursor data should be structured to reveal repeated patterns, weak signals, and emerging operational risks before reportable accidents occur. 2. Barrier and control integrity Safety data should help identify whether prevention barriers, inspection regimes, maintenance practices, training, procedures, equipment, contractor controls, or supervisory assumptions are degrading. 3. Confidentiality and trust The program’s value depends on industry trust. BTS should maintain strong confidentiality protections while ensuring aggregated outputs are useful enough to improve safety decision-making. 4. Data quality and consistency Voluntary reporting in multiple formats reduces participant burden, but BTS should continue improving data normalization, taxonomy, causal-factor classification, and cross-operator comparability. 5. Contractor and supply-chain visibility Offshore safety depends not only on operators but also contractors, OEMs, critical service providers, and specialized equipment vendors. The program should encourage participation across the full operational ecosystem. 6. AI-informed analysis with safeguards BTS’s exploration of large language models and AI-informed analysis could improve detection of patterns in complex safety data. However, AI use should be governed by clear validation, human review, confidentiality protections, error controls, and explainability standards. 7. Public usefulness Aggregated reports and dashboards should help stakeholders understand causal trends, operational vulnerabilities, recurring hazards, and intervention opportunities without exposing protected microdata or proprietary information. 8. Post-intervention verification Where safety trends produce recommended interventions, BTS should encourage follow-up analysis to determine whether those interventions reduced precursor events, near misses, or recurring failure patterns. The broader principle is simple: Safety data should not merely document what happened. It should reveal which assumptions failed before the accident. Offshore oil and gas operations involve high-risk, complex systems where small signals can precede major consequences. A strong voluntary confidential reporting program can turn those signals into prevention. PAG / United Grid recommends continued approval of this information collection, with ongoing focus on data quality, confidentiality, causal-factor analysis, AI validation, industry participation, and practical safety outcomes. The program should be measured by whether it improves the ability to detect risk earlier, act sooner, and prevent accidents before they become inevitable. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/