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.  Even if you have established a robust program, a gap analysis can provide input into what areas could use improvement or redefined focus.

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 based on 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 or regulatory updates.

Gap analyses almost always produce a list of action items. Nice to have or do items that fell off the radar may be re-identified during the gap analysis and lead to improvements in your overall program.

Having a knowledgeable individual that is not closely involved with the program conduct the gap analysis provides a fresh set of eyes.  This helps identify items that may be overlooked by someone that is involved with the program on a regular basis.