What Is a Safety Gap Analysis in EHS?

A safety gap analysis in environmental, health, and safety (EHS) compares what’s written in your programs to what’s really happening at the jobsite. It measures compliance against OSHA requirements, ISO 45001, corporate safety standards, or site-specific controls.

It’s a functional review of risk controls, hazard mitigation, and training application. The goal is to spot blind spots that audits miss, especially those that emerge from procedural drift, contractor variability, or inconsistent supervisor enforcement. OSHA’s guidance on leading indicators and the Campbell Institute’s practical guide both reinforce that organizations must look beyond paperwork to see where controls fail in practice.

Now that we’ve defined what a safety gap analysis is, the next step is knowing when to run one for the most impact.

When Should Safety Leaders Conduct a Gap Analysis?

You don’t need to wait for an audit. In fact, if you do, it’s already too late. OSHA advises program evaluations at least annually, after changes, or when incidents occur. ISO 45001 calls for regular compliance evaluations, which makes gap analysis a practical way to meet those requirements.

Smart safety teams run gap analyses:

  • During program rollouts (e.g. LOTO, confined space, hot work)
  • After a major change in scope or work environment
  • Following a serious incident or near-miss
  • Pre-audit or pre-qualification reviews
  • As part of ISO 45001 clause 9.1.2: evaluation of compliance
  • During quarterly management reviews

The right timing sets the stage, but what does a well-run gap analysis actually look like in practice?

What Are the Core Steps of a Safety Gap Analysis?

Here’s a practical, field-tested process used by leading safety teams in construction, utilities, and infrastructure.

1. Select a Focus Area

Trying to “gap” your entire safety program at once leads to surface-level results. Choose one area with known risk or uncertainty, such as:

  • Fall protection
  • LOTO and hazardous energy isolation
  • Mobile equipment spotter procedures
  • Confined space rescue readiness
  • Contractor onboarding and orientation

Define the scope and set clear audit criteria. Given that BLS fatal injury data consistently shows falls as a leading cause of workplace deaths, and NSC’s Injury Facts track falls as one of the most serious hazards, prioritizing these areas makes sense.

2. Collect Field Data and Evidence

This is where most gap analyses fall short. Don’t rely on what the program says. Find out what crews do. Gather:

  • Field observations of actual work (not staged audits)
  • Completed JHAs and permits
  • Toolbox talk records
  • Interviews with workers and site supervisors
  • Safety training history
  • Equipment inspection logs
  • Incident and near-miss reports

If your LOTO plan says “verify zero energy,” but no one can show how they test it, you have a gap, even if the paperwork looks good. Both OSHA 1910.333 and NFPA 70E’s absence-of-voltage testing make clear that verifying deenergized conditions is not optional.

3. Document Gaps and Risk Ratings

Create a simple table to show what’s working and what isn’t. For each safety control or process, mark whether it’s fully met, partially met, or not met, and add a risk rating based on what’s at stake.

For example:

  • Fully Met: Lockout/tagout is performed by an authorized employee, with testing documented ,  Low risk
  • Partially Met: Lockout is used, but no one verifies energy isolation ,  High risk
  • Not Met: No procedure or training exists for lockout/tagout ,  Critical risk

This approach helps safety teams prioritize fixes based on actual exposure, not just policy gaps.

Include photographic evidence or field notes where possible. If the finding relates to a fatal risk, it must be addressed immediately. The Campbell Institute highlights how organizations must prioritize high-consequence exposures, and NIOSH’s Prevention Through Design program reinforces that eliminating or controlling fatal risks should come first.

A strong process starts with focus. Tools can support the process. Field1st was built to help safety teams take the guesswork out of identifying and fixing safety gaps, especially in high-risk, fast-moving environments.

How Field1st Helps Safety Leaders Close Gaps Faster

At Field1st, we’ve worked with safety teams who needed more than checklists. They needed real-time visibility, field-level engagement, and AI tools that speed up the process, not slow it down.

Our platform supports gap analyses with tools that remove friction and boost precision:

  • Digital Inspections: Build OSHA-aligned checklists that log photos, notes, and corrective actions instantly.
  • Voice1st Forms: Field workers can complete JHAs or inspections using voice, not typing, so nothing gets skipped.
  • AI Risk Prediction: Our models spot patterns in your incidents, inspections, and training to flag high-risk gaps before they escalate.
  • Co-Pilot Chat: Ask any question, about OSHA, site rules, or company procedures, and get a fast, field-ready answer, backed by your own data.
  • Contextual Interventions: If a user selects “confined space” as a hazard, they’re instantly prompted with a site-specific rescue plan or a short safety video before proceeding.
  • Offline Access: In remote areas, workers can still access training videos, emergency maps, and procedures without connectivity.

The result? Gaps are no longer hidden in paperwork. They’re visible, traceable, and fixable, before they lead to the next serious incident. Ready to see how your safety program holds up in the field? Book a demo to see how Field1st helps you uncover and fix safety gaps before they turn into incidents.

FAQs

What is a safety gap analysis used for?

It helps you find where safety procedures, training, or controls are breaking down in the field, so you can fix them before they cause incidents, delays, or noncompliance.

How often should a safety gap analysis be done?

Run one at least once a year, but ideally every quarter or before starting high-risk work. Use them after incidents, scope changes, or major program rollouts.

Who should be involved in a gap analysis?

Safety managers should lead the process, but input from supervisors, field workers, and contractors is essential to get an accurate view of what’s really happening on-site.

How is a gap analysis different from a safety audit?

Audits check if documents meet standards. Gap analyses dig deeper, focusing on how well controls are actually working in the field, even when the paperwork looks perfect.

Can AI improve the safety gap analysis process?

Yes. AI can flag patterns in inspection, incident, and training data to reveal risks earlier, helping teams act faster and prevent repeat failures across sites or projects.