About the GAP Analysis


Once your organization has made a commitment to developing and implementing an EMS and has assembled the EMS Team, the next critical step is to conduct a gap analysis. At the outset of the EMS process, organizations often don’t realize that they already have many components of an EMS or perhaps these components are not documented. The gap analysis is a critical first step because it informs the planning process by telling you what you already have versus what you need to develop. A gap analysis is a series of questions designed to identify whether the facility has:

  • A guiding environmental policy that is supported by management;
  • Secured resources necessary to implement and maintain an EMS; and
  • Systems in place that address, among other things:
o maintaining currency on laws and standards that may be applicable to the facility;
o identification of impacts to the environment and procedures for controlling them;
o performance goals and performance measures for the EMS;
o worker education and training needs relative to the EMS and their job functions
o communication programs for those within the facility as well as outside parties
o record keeping and control of documents
o emergency procedures
o actions to correct deficiencies (compliance and system-wide) and prevent their recurrence; and
o management review of the overall EMS, and a mechanism for making improvements and holding staff accountable for the EMS.

The answers to these questions (and more included in the gap analysis) are usually not strict “yes” or “no” answers. For example, a facility may conduct training, but perhaps records are not kept or the training may be reserved for the most hazardous jobs at the facility. For this reason, a point system may be assigned where for any given question, a facility may score between the minimum and maximum. By graphing out these results – typically against the “ideal” facility for that industry type and size, a process called benchmarking – your facility can then gain a sense of the work that lies ahead in developing the EMS.

(From the Massachusetts Toxics Use Reduction Program EMS Guidance)



This page updated Wednesday July 21 2004