When was the last time you conducted a gap analysis of your EHS program, either by using an outside consultant or an internal resource? If you have never conducted a gap analysis or if it has been some time since the last one, consider investing in this invaluable process.
A gap analysis should start with a thorough review of your EHS needs and an evaluation of the regulatory standards that are applicable to your site and the work being conducted. This should include taking a deep dive into the hazardous materials present and how they are being stored, manipulated, and disposed of. When reviewing compliance with permit and license requirements, consider any permits or licenses that may have been overlooked due to changing needs.
Gap analyses almost always produce a list of action items. Even when an EHS program is well run and well documented, there are usually areas for improvement. Nice to have or do items that fell off the radar may be re-identified during the gap analysis and lead to a major improvement to your overall program.
A knowledgeable individual that is not closely involved with the program should conduct the gap analysis. This helps ensure impartial opinions and considerations, a fresh set of eyes on the program.