Post on 13-Apr-2017
transcript
1 . All Rights Reserved. 7 November 2015 © 3M
Exploring 3M’s Environmental Management Systems
Andrew Willing
October 30, 2015
3M Environment, Health, Safety
and Sustainability
4 . All Rights Reserved. 7 November 2015 © 3M
Lessons Learned
• We did not (initially) understand…
• How our EMS would be used in everyday operation
• Who? For what? – Reference? Work?
• The relationship between the complexity of the
EMS tool and the time & effort to maintain it
• How IT issues (e.g., slowness, login) affect adoption
• We did recognize…
• Too many key decisions or determinations were
decentralized (e.g., email)
• A need for better system to manage & remind 3M’s environmental staff of our compliance
obligations in a changing regulatory and personnel landscape
My opinions
credit: xkcd.com
5 . All Rights Reserved. 7 November 2015 © 3M
Perspective for 3M’s Environmental Management System
The Company
• 100+ U.S. locations with environmental responsibilities
(air, water, and/or waste) in 30+ states
• 850+ environmental licenses, registrations, and/or permits
• 25+ NESHAP/NSPS apply, additional 50+ on watch
Environmental Personnel Organization & Responsibilities
Facility (0-3 per site)
Corporate (20-30)
Operations, Equipment SMEs •
Facility-specific •
Implement permits •
Manage facility EHS •
• Regulatory, Permitting SMEs
• Company/US-wide
• Acquire permits (strategy)
• Support facilities
Andrew Willing
Environmental Specialist
• 3M, 2011-Present
• Environmental permitting,
compliance, auditing
• Previously, env. consulting
Why 3M needs and EMS, and how we use it
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3M’s EMS Wish List ...Ideally in One, Central, On-Line System
credit: xkcd.com
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3M’s EMS Wish List
• Storage for all environmental files, such as:
• Permits, licenses, self-determinations
• Applications, reports, other submittals
• Memos, other internal-only items
• Interactive database, containing:
• Each asset (e.g., emission units, control devices, stacks/vents, etc.)
• Each (applicable) requirement from each state/federal rule (e.g., NSPS), each issued permit
• A detailed statement of compliance demonstration for each applicable requirement
• A detailed statement of basis for each inapplicable requirement
• Management system for environmental tasks (e.g., monitoring, recordkeeping), with reminders
• Management system for environmental projects (e.g., permitting)
• Process flow understanding (i.e., diagrams)
• Potential emissions and calculations
...Ideally in One, Central, On-Line System
credit: xkcd.com
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The Four Tools of 3M’s EMS – Tool One Record of Analysis (ROA)
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The Four Tools of 3M’s EMS – Tool Two Air Core Information Systems (AirCIS)
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The Four Tools of 3M’s EMS – Tool Three Proprietary System
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The Four Tools of 3M’s EMS – Tool Four Compliance & Auditing Metrics & Management System (CAMMS)
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3M’s EMS Tools, in (Brief) Detail
ROA
“Glorified permit mark-up”
Step 1
• Compare permit versions
(if applicable)
• Parse permit into assets and
“actionable” requirements
• Identify state vs. federal
rules
AirCIS
“Facility-wide process-flow
diagram”
Step 2
• Diagram (changes from)
Step 1
CAMMS
“Online, sortable, relational
database”
Step 3
• Input Step 1
• Document the compliance
demonstration for each
requirement
• Set reminders for timely
events
Step 0
• Create (& incorporate data
into) projects for changes
Through the “Management of Change” Lens
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A Bit More on CAMMS – Additional Details
Multi-media, by design
• Air, Water, Waste
• “Other”, Corporate policies, expectations
Understanding “Applicabilities”
(e.g., certain state stormwater permits)
• Entered into system only once
• “Applicable” flag for each facility/asset:
yes / no / under review
• Saves labor, avoids errors (3M & agency)
• E.g., also for NESHAP/NSPS
Fun Facts
• 20,000+ requirements
• 12,000+ obligations
• 36,000+ tasks
• 6,400+ assets
• Includes every 3M employee
• Hierarchical permissions & access
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A Bit More on CAMMS – Handing Permits
“Assets”
Compliance & Auditing Metrics &
Management System (CAMMS)
Requirements
“Obligations”
“Tasks” w/
Reminders
Record of Analysis (ROA)
(an “Authority”)
credit: xkcd.com
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CAMMS Project
A Bit More on CAMMS – Handing Projects
“Assets”
Compliance & Auditing Metrics &
Management System (CAMMS)
Requirements
• New Permit
(Application)
• Memo
• Regulatory
Interpretation
• Other
(an “Authority”)
credit: xkcd.com
CAMMS Project
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The Four Tools of 3M’s EMS
Record of Analysis (ROA)
Compliance & Auditing Metrics &
Management System (CAMMS) Air Core Information Systems
(AirCIS)
Proprietary System
17 . All Rights Reserved. 7 November 2015 © 3M
The Four Tools of 3M’s EMS
Record of Analysis (ROA)
Compliance & Auditing Metrics &
Management System (CAMMS) Air Core Information Systems
(AirCIS)
Proprietary System
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Recommendations Summary
Document centrally
• Avoid re-creating the wheel
K.I.S.S.
• Updating your information should be simple
• One size (or tool) may not “fit all”
MOC is key
• Ensure outdated information can get updated, quickly, easily, and in a central location
My opinions, again