3M has developed an environmental management system (EMS) using four main tools - the Record of Analysis, Air Core Information Systems, a proprietary system, and the Compliance and Auditing Metrics and Management System. The latter system (CAMMS) acts as a central, online database that incorporates data from the other tools. It contains over 20,000 requirements, 12,000 obligations, and 36,000 tasks across 6,400 assets. CAMMS aims to centrally manage 3M's environmental compliance information and reminders across its 100+ U.S. locations. The presentation recommends maintaining information centrally using a simple system that allows for easy updating through a management of change process.

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Exploring 3M’s
Environmental
Management Systems
Andrew Willing
October 30, 2015
3M Environment, Health, Safety
and Sustainability

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credit: xkcd.com

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Lessons Learned
My opinions
credit: xkcd.com

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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

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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

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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

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Recommendations Summary
My opinions, again

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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

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Thank you