Regulatory Strategies

With 24 years with a multinational company whose diversity reflects industry as a whole, plus experience working in government (both US EPA and Minnesota Pollution Control Agency), extensive trade association interaction with other companies, agencies and NGOs, and backed by technical degrees, Georjean Adams has a unique “multi-cultural” perspective. She can understand and communicate with business, technical, public interest group and government representatives to hone in on common goals and practical implementation programs.

Persistent chemicals review process preventing risks associated with incorporation of persistent chemicals and enhancing consistency and efficiency. 3M executive management determined that the company
needed an ongoing process to review existing uses of all persistent chemicals and prior to any new uses. Georjean worked with the corporate executive EHS committee to create a policy and subsequent processes to manage these reviews. Using existing databases on composition and production and working with the product responsibility liaisons within using divisions, She led a task group in defining coverage and developing
a prioritization of chemicals for review, a database package requirement and a review process that determines appropriate management action or may prohibit use of persistent chemicals. The process is now completing
its second round of prioritization and efficiently reviewing proposed new uses.

New process to document exposures with a 10-fold reduction in resources. The project involved developing a Process to document risk of exposure to highly toxic chemicals in labs. She successfully tackled the need to document whether any of the 1100 users of a list of toxic chemicals required medical surveillance. Using Six Sigma tools and the philosophy of understanding existing systems and needs, Georjean created a screening mechanism to quickly eliminate from concern and document ~85% of the users. She utilized existing systems that surveyed users and a database that stored hazard assessments by making modifications and leveraging existing capabilities in conjunction with IT, while at the same time not interfering with the primary purposes of the databases. Georjean had to also convince the corporate industrial hygiene staff that it was not necessary to monitor and conduct risk assessments of all users, which was a strong bias coming from their manufacturing facility biases. She demonstrated that the screening assumptions were valid by collecting sampling data and that from a practical basis, we did not have the kind of standardized operations they were familiar with in our labs, nor did we have IH staff to conduct lab by lab, researcher-specific assessments in all cases. They agreed that assessments by a CIH of the remaining 15% would be sufficient. We were thus able to complete survey and documentation of all lab activities in 6 months. Georjean established a sustainable step-by-step SOP that can easily deal with changing chemicals and users with limited resources.

Regulatory expertise to efficiently maintain compliance and to negotiate reduced or no fines. By understanding the underlying intent of regulations and what regulators are concerned about, Georjean has been able to design processes for record keeping and notification and negotiate with US EPA to limit economic impact on 3M.
Negotiated the first PMN that covered a class of chemicals, allowing 3M to manufacture a range of materials meeting a certain set of criteria without separate notification and delay.
Leveraged database to identify potentially impacted products/businesses to efficiently collect data for reporting rules and substantiate reports to EPA TSCA inspectors.
Strategized with businesses to devise regulatory strategies to obtain variances that improved 3M’s market position (California VOC SCAQMD and CARB).
Eliminated unnecessary signature control process that had created delay in laboratory record keeping and occupied significant staff time to monitor due to a misinterpretation of OSHA standards.
Influenced clarification of TSCA 8e in 3M and CMA negotiations to eliminate potential significant penalties.