4.4 Implementation and Operation

4.4.1 Organizational Structure and Environmental Roles and Responsibilities
To facilitate effective environmental management, roles and responsibilities related to the EMS are assigned. Authority is granted, commensurate with each employee's responsibilities. A general description of the organizational structure and environmental roles and responsibilities is provided in this section. The various procedures referenced in this EMM provide further detail on the assigned roles and responsibilities.

The Director of PW defines the PW environmental policy. He ensures the provision of resources (human resources, including specialized skills; technology resources; and financial resources) for the operation of the EMS. He conducts periodic management reviews of the EMS to ensure its effectiveness and appropriateness to the PW mission and processes. He appoints the EMS Management Representative.

The Deputy Director of PW assists the Director in carrying out top management's EMS responsibilities. The Deputy acts for the Director in the Director's absence.
The EMS Management Representative is appointed by the Director of PW. The EMS Management Representative reports to PW top management (Director, Deputy Director).

The EMS Management Representative has overall responsibility and authority to implement and manage the day-to-day operation of the EMS. Irrespective of other responsibilities, the EMS Management Representative's responsibilities include the following, with the requisite authority to accomplish them:

Ensuring the EMS is established, implemented and maintained in accordance with the current version of the International Standard ISO 14001 while supporting accomplishment of the environmental management responsibilities of PW.

Periodic reporting to PW top management on the performance of the EMS.

The chart at Figure 2 outlines the functional organization within which the EMS operates. The chart also shows the interrelationships among the key individuals involved in the operation of the EMS within PW.

The EMS Management Representative is supported and assisted by the following:

A multi-Division Process Analysis Committee, appointed annually or as required, which updates PW processes, activities and services, reviews the PW significant aspects, and provides input for PW environmental objectives and targets.

One or more multi-Division Management Program Teams, appointed annually or as required, to develop and coordinate implementation of management programs for the PW environmental objectives and targets.

One or more technical support personnel who obtain data, conduct research, prepare reports, and perform other EMS-related tasks as needed.

Internal auditors who are selected from throughout PW, trained, and who conduct PW internal audits. The EMS Management Representative maintains the roster of PW internal auditors.

A Document Control Coordinator who performs administrative functions in support of the document control system.

PW Division Chiefs implement the EMS within their divisions, providing the needed management support and resources to do so. They coordinate with and provide appropriate assistance to the EMS Management Representative for PW-wide EMS requirements or initiatives. They participate with the Director of PW in the conduct of periodic EMS management reviews.

The Chief, Environmental and Natural Resources Division (ENRD) is responsible for environmental program management for the entire Fort Lewis installation, which includes PW as a subordinate organization. He is the Fort Lewis On-scene Coordinator for emergency responses to hazardous substances or releases, and is responsible for maintaining the Fort Lewis Installation Spill Contingency Plan (ISCP). As a PW Division Chief, the Chief of ENRD has EMS-related responsibilities as previously stated.

The Chief of ENRD supervises the following individuals who have EMS-related responsibilities:

ENRD Program Managers who manage specific Fort Lewis environmental programs and/or plans for media protection and resource conservation including air, groundwater, surface water, soil, cultural resources, pollution prevention, etc.

A Compliance Inspection Team that schedules and conducts periodic environmental compliance inspections of Fort Lewis organizations, including PW.

An Environmental Operating Certificate Coordinator who prepares and maintains Environmental

Operating Certificates for Fort Lewis organizations, including PW. An environmental operating certificate is a one-source environmental management document tailored for the organization which describes the organization's processes, environmental aspects, legal and other requirements, hazardous materials used and hazardous wastes generated, training and documentation requirements, and other pertinent information such as recommended best management practices for pollution prevention.

Procedures have been established and roles and responsibilities assigned for EMS planning activities (including the identification of environmental aspects and impacts, identification of legal and other requirements, and the establishment of objectives and targets, as well as the programs necessary to achieve those goals).

Operational control responsibilities include, but are not limited to, process and hazardous waste handling, implementing procedures, monitoring and measurement, document control, and training. Trained individuals in each activity area manage environmental awareness and operational controls.

Any cognizant employee may identify problems and initiate action to isolate nonconformities related to a procedure, process, work instruction or any element of the EMS. Responsibility and authority for recording problems, initiating and recommending problem solutions and preventive actions, verifying solution implementation, and controlling nonconforming products until corrections have been implemented are defined in PW procedure EMS-255, Preventive and Corrective Action.

Emergency response procedures are detailed in the Fort Lewis Installation Spill Contingency Plan (ISCP). Site-specific emergency response plans are prepared, and periodic familiarization training is provided to employees at the worksite.

EMS Management Reviews are conducted at least annually by the Director of Public Works with the PW Division chiefs. PW procedure EMS-270, Environmental Management Review (available on the PW Intranet), describes the management review process. Management Review meetings include a review of the overall system, internal audit results and corrective action status, and other matters relevant to operation and effectiveness of the EMS.

The Director of Public Works and the PW Division Chiefs oversee environmental compliance and health and safety programs (in coordination with MAMC Industrial Hygiene office and the Installation Safety office) in the workplace.