Why Your College or University EH&S Program Needs a Gap Assessment

and   |   April 16, 2019

Colleges and universities face a wide-range of occupational health and safety risks and environmental compliance challenges. With so many institutional operations and changes, it’s all too easy for even the most carefully developed environmental health and safety (EH&S) programs to become out of date and out of compliance, creating potentially dangerous and costly gaps.

These gaps occur in a variety of ways — making them even more challenging to identify. For example, if your institution has construction taking place on campus your EH&S program may be responsible for ensuring construction site safety, including oversight of fall protection and routine safety programs. In the flurry of construction activity that typically occurs on campuses between May and September, some requirements may get overlooked. Gaps can also occur in laboratory safety programs when a new research procedure is introduced (the EH&S staff is often the last to be informed). This becomes especially challenging to track on campuses with a large number of laboratories and can lead to potential hazards for members of the university community.

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An EH&S gap assessment can help identify vulnerabilities in your program and ensure your institution isn’t blindsided with an incident or risk that could have been avoided. But let’s back up. What is an EH&S program gap assessment?

What a Gap Assessment Is — and What It’s Not

Conducted by an independent third party, a gap assessment of your EH&S program is exactly what its name suggests: an assessment of any potential regulatory or safety gaps in your program. A comprehensive gap assessment also evaluates the management systems and lines of communication you have in place to support your program. A gap assessment is not about “catching” your institution in any wrongdoing. The compliance and safety experts who conduct the gap assessment don’t report any areas of non-compliance to regulatory agencies.

A gap assessment is designed to work in partnership with the director of your EH&S program to improve the overall health and safety of your campus. When done correctly, it is tailored to your institution’s needs and operations and configured so that it does not generate a lot of extra work for your EH&S staff. In addition, findings can be used to help focus resources to address program vulnerabilities with the highest risk.

How do you know when it’s the right time to invest in a gap assessment?


3 Key Reasons Your Institution Needs a Gap Assessment

Some colleges and universities wait until their institution has gone through a big change to have a gap assessment conducted. Other institutions periodically conduct a gap assessment to ensure their EH&S program remains up-to-date and compliant. Below are examples of key reasons your institution may need a gap assessment sooner rather than later.

Regulations Change

Regulations are frequently updated, and your institution may become subject to new regulations. For instance, in 2017, the Occupational Safety and Health Administration (OSHA) changed their standards related to silica. If your EH&S program hasn’t been updated since this regulation took effect, you may not be in compliance or you may not know how this new standard may apply to your institution.

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Institutions Change

College and university campuses are characterized by constant activity and change. The arrival of new principle investigators requires important steps to ensure sufficient safety staff is available to support their research. A professor starting new research that involves recombinant DNA will require the preparation of materials for Institutional Biosafety Committee (IBC) review and approval — an IBC is a key part of compliance in order to receive funding from the National Institute of Health. With such a broad scope of activities and purposes, these types of changes can be especially difficult to manage.

People Change

It’s not uncommon to have frequent turnover, particularly in those positions that are conducting lab inspections and educating new faculty. Employee turnover creates an increased likelihood that gaps will arise without being addressed.

These three reasons are the most common causes of potential safety issues and breeches in compliance that a gap assessment can catch. Beyond catching compliance gaps, a gap assessment can bring other benefits to your campus.


3 Added Benefits of a Gap Assessment

Discovering What’s Working

One of the biggest advantages of the gap assessment process is confirmation of what aspects of your EH&S program are working well. A third-party affirmation that current campus efforts are successful helps validate your program and the performance of EH&S staff.

Providing an Outside Perspective

Many EH&S directors are well aware of the issues on their campus — they can identify exactly what gaps exist in their program. Having that independent report from third-party compliance and safety experts brings a fresh outside perspective. Institutional leadership or other departments may be more open to ideas presented by a qualified outsider.

An independent expert can also serve as a different voice to help resolve issues between departments on a campus. Let’s take roof safety as an example. It’s not uncommon for there to be disagreements between the EH&S director and the director of facilities as to the proper procedures for roof safety and, specifically, in identification of the hazards that are present and the steps to address them. A third-party expert can help both sides reach a conclusion that allows projects to be well managed, while also ensuring worker safety and regulatory compliance.

Identifying Weaknesses

In addition to identifying clear gaps, your assessment can also identify weaknesses and the relative risk of those weaknesses. This knowledge can help guide your attention and resources to the areas where they are most needed.

A gap assessment is a low-cost, accessible way to fortify your EH&S program and ensure your college or university is safe and compliant — no matter the challenges your campus faces. You’ll have an accurate picture of vulnerabilities, ranked by risk, and a clear path for improvement. By enlisting a third-party review, you can determine how effective your program is and validate the need for additional resources to address identified risks.

Want to know more about how an EH&S gap assessment can benefit your program? Get in touch with us today!