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Robert Bray

Mr. Bray is a Managing Director of The Elm Consulting Group LLC., an independent environmental, health, and safety consulting practice. Mr. Bray has 18 years of experience in regulatory compliance and environmental, health and safety management, helping clients from the petrochemical, aerospace, consumer product manufacturing, primary and secondary metals, pharmaceutical, food, printing and utility industries understand the complex and ever-changing environmental regulations and policies. Mr. Bray's specific environmental, health and safety management experience includes assisting several large corporations in the design and implementation of auditing programs and environmental management systems by conducting training, developing state- and industry-specific audit protocols, developing audit report formats, designing databases to store and track audit information, and leading audit teams in the field. The following are examples of Mr. Bray's project experience:

• Mr. Bray has conducted more than 450 compliance/management systems audits nationwide. He has managed a number of other projects for clients as well, such as developing facility-specific environmental procedures manuals, conducting environmental, health and safety awareness training, performing targeted regulatory and statutory research, conducting waste characterization and hazardous wastes management.
• Assisted a petroleum corporation in developing an environmental, health and safety compliance audit program to identify liabilities at up-stream and downstream petroleum operating facilities and pipelines. The audit program consisted of developing local, state and federal audit protocols, conducting EH&S compliance audits, and reporting and database tracking system development. Results of the audits were utilized by facility and corporate staff to identify resource requirements, develop an environmental management system, and reduce compliance liabilities. Follow-up audits revealed compliance at facilities had improved significantly.
• Project manager for a division environmental, health and safety audit program for marketing terminals, marine terminals, pipelines and associated equipment, and vessels. Responsibilities included developing facility-specific audit protocols and an audit protocol management database, auditor training, scheduling, staffing, and acting as audit team leader. The audits entailed an evaluation of all major environmental, health and safety, DOT, and Coast Guard requirements as well as compliance with corporate guidelines. Recommendations based on audit findings were provided to develop revised environmental management systems.
• Evaluated the applicability of California storm water regulations associated with petroleum operations at terminals, lube oil blending, and pipeline facilities. Results of the projects were used to conduct storm water permitting and develop best management practices.
• Evaluated environmental management systems and conducted audits to identify management systems in place and evaluate the implementation of such systems. The results of the assessments were used to develop training for facility environmental, health and safety representatives in the development of systems to maintain day-to-day compliance with regulatory requirements.
• Performed comprehensive compliance audits at pharmaceutical/medical device manufacturing facilities located throughout the U.S., engaged in production (tablets, capsules, liquids and sterile injectables), medical equipment, and pilot scale chemical development. Audited facilities for compliance with federal and state regulations governing solid, hazardous and medical waste management, air emissions, emergency planning and right-to-know, USTs, wastewater discharges, drinking water, and PCBs. Briefed facilities environmental staff and division counsel on compliance status and ranked deficiencies according to corrective action priority.
• Conducted management systems audits of large aerospace facilities to determine causes of non-compliance with environmental regulations and provided recommendations to eliminate these causes. Project consisted of conducting a multi-media compliance audit and interviewing key facility and corporate personnel to evaluate the environmental management activities at the facility and corporate levels. Recommendations were made to revise existing management systems to reflect operation philosophies. A follow-up assessment revealed the facilities had reduced compliance deficiencies through the implementation of recommendations.
• Responsible for developing and implementing environmental, health and safety programs for an aluminum casting facility. Responsibilities included day-to-day compliance with applicable EH&S regulations ad corporate policies, air and wastewater permitting, industrial hygiene monitoring, accident investigation, emissions control system design, subsurface investigation and remediation project management, facility closure activities, waste pile characterization, building decontamination, and EH&S training.
• Developed a facility specific hazardous waste management plan for use by facility employees in the management of hazardous waste at an interim status facility.
• Mr. Bray received a B.S. in Environmental Science from the University of California. In addition, Mr. Bray is a Certified Professional Environmental Auditor and has successfully completed the ISO 14000 Lead Auditor course. He is a member of the Auditing Roundtable, including the Chair of the Leg and Regs Committee, and has lead several forums.