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3E Fuels Shell's EHS Compliance Management
Shell Oil is a global group of energy and petrochemical companies with around 102,000 employees in more than 100 countries and territories. Shell continually places a strong emphasis on environmental regulatory compliance, and the company is committed to managing its environmental impact as it strives to meet the world’s growing energy needs.
As a large global company, Shell faces many challenges in its quest to achieve environmental regulatory compliance in the context of constantly changing international regulatory initiatives.
The company is burdened with identifying, tracking, maintaining, and complying with international regulatory guidelines to protect the health and safety of employees and consumers, as well as the environment. The regulations, initiatives, and directives devised and enforced by regulatory and governing bodies throughout the world are individually published in a variety of formats and locations. This information is scattered amongst hundreds of disparate sources and is not easily shared among various personnel within a company who need to reference it. Most recently, compliance with the EU’s REACH (Registration, Evaluation and Authorization of Chemicals) and with all of the national implementations of the United Nation’s Globally Harmonized System has been an especially time-consuming task.
“Complying with REACH is a huge challenge for us,” said Allen Schmit, Global Manager of Product Regulatory Support, Shell. “I would estimate that this is where we are spending the greatest amount of time right now.”
“Keeping up with GHS implementation around the world has also been quite difficult,” continued Mr. Schmit. “Our regulatory team is constantly working to stay on top of who is doing what, and what is happening where. We have found it increasingly difficult to plan ahead and design systems to meet regulatory requirements that are a moving target.”
Challenges resulting from changing regulatory initiatives have also impacted Shell’s ability to efficiently and effectively produce and maintain the currency of SDSs, labels, and other hazard communication documents for its products. Effective, compliant, and up-to-date documents—especially SDSs—are not only a global requirement, but serve as the critical foundation for facilitating and supporting best practices for effective product stewardship throughout the product's lifecycle. With high standards for quality, Shell recognized that merely producing an SDS is not enough. Quality, accuracy and currency are critical components in fulfilling the original intentions for requiring such documentation in the first place. To produce these top-quality documents, Shell needs access to comprehensive and reliable regulatory content.
The Company was also burdened with a massive SDS Authoring workload and was searching for a reliable and reputable service provider that could offer supplemental assistance during peak periods of especially high volume.
Integrated Content for SAP
Shell employs 3E Optimize into their SAP EHS Management system in order to optimize the authoring of GHS and otherwise compliant SDSs. In fact, Shell relies on the seamless integration of 3E Optimize content into their SAP EHS system for a wide range of processes.
SAP EHS Management can only be optimized when comprehensive content, prepared by regulatory experts, is integrated into the application. This content includes regulatory data covering the geographical scope of the user's business, Expert Rules to automate checking products against regulations and running complicated classification calculations, a library of phrases covering each of the languages which need to be used for documents, and document templates reflecting the current regulatory requirements and best practice for each of the countries in the user's business scope.
Shell relies on integrated content for their SAP EHS Management system for use by their team of authors. Having centralized access to comprehensive, current global chemical and regulatory information significant reduces the amount of time required to author compliant documents.
“Shell has been relying on integrated content solutions for the last ten years,” said Mr. Schmit. “The breadth and depth of their coverage is unparalleled, with extensive coverage of regulated chemicals throughout the world at multiple levels of jurisdiction.”
Indeed, the Company’s enduring relationship with 3E has been mutually beneficial; as an early subscriber of 3E Insight for Chemicals, Shell has significantly influenced the development of 3E’s unique SAP content integration tools, which optimize the loading and management of 3E Insight for Chemicals in SAP solutions.
When Shell’s internal authoring team needs supplemental assistance during the inevitable ebb and flow of workload, Mr. Schmit reaches out to 3E for assistance in authoring Safety Data Sheets (SDSs). The Shell team and the 3E Authoring team collaborated to devise a strategy for authoring the new documents quickly and efficiently. The solution was for 3E’s Authoring experts to access Shell’s own SAP EHS Management platform via a co-sourcing arrangement.
This arrangement has enabled 3E and Shell to collaborate on the authoring and production of SDSs from Shell’s own authoring system. 3E’s authors utilize secure, remote access to Shell’s platform in order to perform authoring activities. 3E’s own team of multilingual authors follow Shell’s corporate authoring guidelines and a collaboratively developed formal review and approval process that results in the most efficient and cost-effective solution.
The strategy has been very successful, with 3E efficiently authoring accurate and compliant documents in accordance with Shell’s deadlines. In fact, the strategy has been so successful that during the course of its multi-year relationship, 3E has completed a number of critical Authoring projects for Shell.
In 2008, the Company undertook a project with a demanding timetable for Shell’s Downstream business. As part of the project, 3E was tasked with completing work on specific sections on 1500 of Shell’s lubricant SDSs. The project began in September 2008 and needed to be completed by November 30, 2008. 3E’s Authoring team completed the documents by the stated deadline, and eventually received additional documents for completion in December. More than 1600 documents were authored in five months.
The Authoring team also handled two projects for Shell in 2009. The team assisted in a migration project for multiple Vietnamese SDSs in which they extracted legacy documents from an existing system and populated that data into Shell Downstream’s SAP EHS Management system. The team also completed Authoring work for Shell’s lubricant products, creating an additional 110 documents.
Most recently, 3E authored close to 100 documents for Shell’s low boiling point naphtha and heavy fuel oil products as well as additional documents for Shell’s Fuels products. In addition, 3E, together with Shell, participated in the review and audit of more than 300 documents which had been updated to meet the new marine pollutant regulations.
3E Insight for Chemicals
The Company also relies on 3E Insight for Chemicals, an online chemical regulatory compliance reference tool that puts the regulatory data for Shell’s global EHS compliance programs one click away. 3E Insight for Chemicals intuitive web browser interface provides access to accurate, comprehensive, up-to-date, and usable regulatory content that can be used to ensure compliance with local, state, federal regulations, as well as international regulatory initiatives like REACH and GHS.
Shell currently has 175 3E Insight for Chemicals users. They rely on 3E Insight for Chemicals as a research tool that provides the necessary information to support decisions related to a variety of business issues that must be considered when manufacturing products, such as:
- Making sure SDSs are compliant within the markets in which the products are sold
- Making sure labels are acceptable in the destination market
- Identifying regulatory authorities who require notification when exporting
- Knowing which agencies have to be notified in the event of a chemical release or spill
- Ensuring products can be sold in the intended markets
3E Insight for Chemicals provides and allows access to the regulatory data, which provides full text documents as well as compliance guides, in addition to extensive coverage of regulated chemicals throughout the world at multiple levels of jurisdiction, from international, U.S. federal and state, to European Union as well as EU Member States and non-member states.
The data also contains transportation related data as well as chemical property and hazard data. Since Shell is a global company, it employs all content modules, including North America; European Union and Western Europe; Central and Eastern Europe; Latin America; Asia-Pacific; Middle-East/Africa; Global Inventories; RegsLink US Code of Federal Regulations (CFRs); Chemical Property and Hazard Data, RegTrans Transportation Data, ChemEXPERT Phys/Chem. Tox Eco Tox Data.
Shell and 3E have enjoyed a productive relationship for more than ten years. Shell has been very pleased with Verisk 3E’s comprehensive suite of chemical, regulatory and compliance information services throughout the years. The company relies on Regulatory Content as the foundation of multiple business decisions, but also to assist in the creation and development of accurate and compliant SDSs.
“We have also found great value in 3E’s SDS Authoring Services; the 3E team has been instrumental in helping us understand what we need to deliver with our SDSs,” said Mr. Schmit. “Since the regulations are constantly changing, we greatly appreciate their relevant and expert support and advice.”
Location: Houston, TX, USA
3E Services: 3E Optimize, 3E Insight for Chemicals, SDS Authoring Services
Industry/Market: Energy & Petrochemicals
Company Web Site: http://www.shell.com