Andrew Willing, 3M, Exploring 3M's Environmental Management Systems

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


credit: xkcd.com


Lessons Learned

My opinions

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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


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


3M’s EMS Wish List ...Ideally in One, Central, On-Line System

credit: xkcd.com


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


The Four Tools of 3M’s EMS – Tool One Record of Analysis (ROA)


The Four Tools of 3M’s EMS – Tool Two Air Core Information Systems (AirCIS)


The Four Tools of 3M’s EMS – Tool Three Proprietary System


The Four Tools of 3M’s EMS – Tool Four Compliance & Auditing Metrics & Management System (CAMMS)


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


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


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


CAMMS Project

A Bit More on CAMMS – Handing Projects

“Assets”


Management System (CAMMS)

Requirements

• New Permit

(Application)

• Memo

• Regulatory

Interpretation

• Other

(an “Authority”)

credit: xkcd.com

CAMMS Project


The Four Tools of 3M’s EMS



Management System (CAMMS) Air Core Information Systems

(AirCIS)

Proprietary System


Recommendations Summary

My opinions, again


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


Thank you

Andrew Willing, 3M, Exploring 3M's Environmental Management Systems

Environment

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