OSHA Gap Analysis and Assessment Requirements

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OSHA Gap Analysis and Assessment: Requirements

Ensuring environmental and workplace safety is not just best practice—it’s the law. The Occupational Safety and Health Administration (OSHA) enforces strict compliance standards that employers must follow. One of the most effective ways to meet these expectations is by conducting an OSHA Gap Analysis or OSHA Assessment.

This “OSHA Gap Analysis Requirements” guide breaks down OSHA’s key EH&S audit expectations, what companies need to know, and how to stay compliant through proactive assessments.

Understanding EH&S Compliance

EH&S compliance refers to an organization’s adherence to environmental regulations and occupational safety laws. OSHA focuses on protecting workers from workplace hazards, while the EPA enforces regulations that protect the environment and public health. Both agencies have enforcement power and issue fines, penalties, and citations for noncompliance.

A structured EH&S audit is essential for identifying a company’s compliance with these regulations and providing an opportunity to fix issues before they become legal liabilities.

OSHA EH&S Audit Requirements

OSHA does not mandate EH&S audits per se, but it strongly encourages them as part of a comprehensive safety and health management program. OSHA audits typically involve:

1. Hazard Identification and Risk Assessment

Employers must assess the workplace for potential hazards, including chemical exposure, noise, fall risks, confined spaces, and equipment safety. OSHA audits evaluate whether appropriate hazard controls are in place.

2. Compliance with OSHA Standards

Audits examine adherence to federal OSHA standards, including but not limited to:

  • 29 CFR 1910 (General Industry)
  • 29 CFR 1926 (Construction)
  • Hazard Communication Standard (HazCom)
  • Respiratory Protection Standard
  • Lockout/Tagout (LOTO)
  • Confined Space
  • Electrical Safety
  • Powered Industrial Truck (PIT)

3. Written Safety Programs

Depending on the industry, employers must maintain written programs for hazard communication, emergency action, bloodborne pathogens, and other safety protocols. OSHA auditors verify that these programs exist and are implemented.

4. Employee Training Records

Training is critical for compliance. OSHA audits review whether employees have received initial and refresher training in required areas and whether these sessions are adequately documented.

5. Recordkeeping and Reporting

OSHA requires businesses with over 10 employees in specific industries to maintain OSHA 300 logs, record work-related injuries and illnesses, and report fatalities or severe injuries within particular timeframes. An EH&S audit ensures this data is recorded and reported accurately.

EPA EH&S Audit Requirements

Like OSHA, the EPA does not require formal EH&S audits but offers incentive programs and guidelines encouraging self-disclosure and corrective action regarding environmental violations.

Key areas covered in an EPA-aligned audit include:

1. Hazardous Waste Management (RCRA)

The Resource Conservation and Recovery Act (RCRA) mandates proper handling, storage, and disposal of hazardous waste. An EH&S audit checks for:

  • Accurate waste classification
  • Correct labeling
  • Secure storage
  • Timely disposal
  • Proper manifesting

2. Spill Prevention, Control, and Countermeasure (SPCC) Plans

Facilities storing large quantities of oil or hazardous substances must maintain SPCC plans. Audits verify that plans exist, are updated, and are correctly implemented.

3. Stormwater Pollution Prevention Plans (SWPPP)

Under the National Pollutant Discharge Elimination System (NPDES), construction and industrial sites are required to manage runoff. EH&S audits assess whether a SWPPP is in place and being followed.

5. Emergency Planning and Community Right-to-Know Act (EPCRA)

Companies that store or release certain chemicals must report this information to local authorities. Audits confirm that these reporting obligations are being met.

EPA’s Audit Policy and Incentives

The EPA promotes voluntary environmental audits through its Incentives for Self-Policing: Discovery, Disclosure, Correction, and Prevention of Violations policy. Key benefits include:

  • Reduction or elimination of penalties if companies voluntarily discover and disclose violations.
  • No recommendation for criminal prosecution if conditions are met.
  • Encouragement to implement environmental management systems (EMS).

To qualify, companies must meet conditions such as:

  • Discovery of the violation through a voluntary audit.
  • Prompt disclosure (within 21 days).
  • Correction within 60 days.
  • No harm to public health or the environment.
  • Prevent the recurrence of the violation.
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Benefits of Aligning EH&S Audits with OSHA and EPA

Conducting EH&S audits with OSHA and EPA standards in mind offers several advantages:

  • Avoid regulatory fines and citations.
  • Reduce worker injuries and illnesses.
  • Improve environmental performance.
  • Qualify for regulatory incentives.
  • Boost organizational reputation.
  • Strengthen internal compliance culture.

Common Gaps Found in OSHA and EPA Audits

During EH&S audits aligned with OSHA and EPA requirements, organizations often discover the following issues:

  • Expired or missing environmental permits.
  • Inadequate chemical hazard communication.
  • Improper waste labeling or accumulation.
  • Outdated or missing emergency response plans.
  • Lack of PPE enforcement or training.
  • Poor housekeeping or facility maintenance.
  • Missing or incomplete injury/illness logs.

Identifying and correcting these issues before a regulator finds them helps businesses avoid costly consequences.

Best Practices for EH&S Audit Compliance

To maximize the effectiveness of OSHA and EPA-compliant EH&S audits, organizations should:

  1. Stay updated on regulatory changes.
  2. Conduct routine internal audits.
  3. Hire third-party EH&S professionals for external audits.
  4. Maintain robust documentation systems.
  5. Implement corrective action programs.
  6. Train employees regularly on safety and environmental topics.
  7. Keep communication open between departments and leadership.

Your Compliance Partner for OSHA and EPA EH&S Audits

Meeting OSHA and EPA expectations requires diligence, expertise, and an ongoing commitment to compliance. EH&S audits, when properly designed and executed, are the most effective method of achieving these goals.

Get EH&S Audit Support from Phase Associates

Phase Associates specializes in Environmental Health and Safety audits that meet the rigorous standards of OSHA and the EPA. Whether you need help identifying hazards, reviewing environmental permits, or preparing for a regulatory inspection, Phase Associates can guide your team to full compliance.

Contact Phase Associates today to schedule an OSHA Gap Analysis and Assessment and an EPA-aligned EH&S audit to protect your business from regulatory risk.