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What to Expect: The EHS Gap Assessment Process

If you’ve decided your facility needs an outside look at its EHS programs (or someone above you has decided), the next question is practical: what actually happens?

A gap assessment isn’t a surprise inspection. It’s a structured review, scheduled on your timeline, designed to give you a clear picture of where your facility stands on environmental, health, and safety compliance. Here’s how it works from start to finish.

Before We Arrive

The process starts before anyone sets foot on your property. We send a document request asking for the materials that let us understand your facility’s current compliance posture before the site visit. This typically includes your Injury and Illness Prevention Program, Hazardous Materials Business Plan, training records, permits, Safety Data Sheet (SDS) inventory, waste manifests, and any previous inspection reports or audit findings.

Some facilities have all of this organized and ready to go. Others aren’t sure what they have, or where it is. That’s fine. The state of your documentation is itself useful information. If you can’t locate your IIPP or your last CERS submission (the state’s online environmental reporting system), that tells us something important before we even arrive.

We review what you send so the on-site visit is focused and efficient. We’re not starting from zero when we walk through your door.

The On-Site Walkthrough

On site, we walk the facility with your team, usually the person responsible for EHS, a facility or operations manager, or whoever knows the day-to-day operations best.

We’re comparing three things: what your documents say, what the regulations require, and what’s actually happening on the floor. That means looking at operations, storage areas, signage, equipment conditions, and employee practices. We check that chemicals are stored compatibly. We look at whether fire extinguishers match the locations shown on the facility map. We observe whether safety procedures that exist on paper are being followed in practice.

The walkthrough also includes conversations with your team. We ask about processes, chemical use, waste handling, training history, and any recent changes to operations or staffing. These conversations often surface information that doesn’t show up in documents: a process change that was never reflected in the SWPPP (your Stormwater Pollution Prevention Plan), a new chemical that wasn’t added to the CERS inventory, a training that was conducted but never documented.

Have questions about what a review of your facility would look like? Call (925) 551-7300. We’re happy to walk you through it.

What You Get: The Assessment Report

After the visit, we deliver a written report organized by regulatory program, not by severity ranking or facility area. Each section covers:

  • The regulatory requirement that applies
  • What we observed at your facility
  • A specific recommendation for how to address it

If your Hazardous Materials Business Plan was filed years ago under an old business name and has lapsed, the report explains the CERS filing requirement, notes what we found, and tells you exactly what needs to happen to get current. If employees were observed working without required personal protective equipment (PPE) despite posted signage, the report identifies the gap between the written program and actual practice, and recommends how to close it.

Every finding comes paired with a solution. You get a compliance picture and a path forward, not just a list of problems.

What the Report Looks Like

ElementWhat It Includes
OrganizationGrouped by regulatory program (hazardous materials, waste, safety programs, environmental permits, training), not by severity
FormatNarrative report for most facilities; compliance matrix for simpler profiles
Each findingRegulatory context → observation → specific recommendation
Summary tableStatus across all reviewed programs at a glance
What it does NOT includeSeverity rankings, cost estimates, implementation timelines, or compliance scores

The report is designed so your team can act on it. Your team (or ours) can use it as a roadmap for what to address and in what order.

What Happens Next

The assessment tells you where you stand. What comes next depends on what we find.

If programs are missing or need to be rebuilt, we scope and price that work based on the assessment findings. This is typically fixed-fee, organized by regulatory program, and prioritized by risk, starting with the areas where a regulatory inspection would create the most exposure. Because the assessment has already identified the specific programs and their condition, the proposal reflects your facility’s actual needs, not estimates.

If programs are in place but need refinement, a more detailed compliance audit may be the right next step, checking each requirement against current practice, line by line. Read more about the difference →

For ongoing compliance, many facilities move into a regular schedule where we visit on a monthly or bimonthly basis, handle regulatory submissions, conduct training, and review programs throughout the year. Learn how ongoing compliance works →

Ready to find out where your facility stands? Call (925) 551-7300 or request a consultation. Tell us what prompted the question, and we’ll walk you through what a review would look like for your specific situation.

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BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
Gerona Goethe · General Manager · Bay Ship

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Tell us about your facility and your deadline. You’ll get a clear read on what applies and a scoped plan to handle it.