The Importance of Conducting a Gap Analysis

In an increasingly regulated and risk-aware business environment, organisations are expected to demonstrate robust management of work health and safety (WHS), quality, and environmental responsibilities. These expectations are driven by legislation, industry standards, customer requirements, and broader societal demands for safe, ethical, and sustainable operations. One of the most effective ways for companies to ensure their management systems meet these obligations is through conducting a comprehensive gap analysis.

A gap analysis is a structured assessment that compares an organisation’s current practices against relevant legal requirements, standards, and best-practice frameworks. When applied across WHS, quality, and environmental management systems, it becomes a critical tool for identifying weaknesses, managing risk, and driving continual improvement.

Understanding Management System Gaps

Management systems such as WHS, quality, and environmental frameworks are often aligned with recognised standards, including ISO 45001 (Work Health and Safety), ISO 9001 (Quality), and ISO 14001 (Environmental Management). However, simply having policies or certifications in place does not guarantee compliance or effectiveness.

A gap analysis examines the difference between what is currently being done and what should be done to meet:

  • Legislative requirements (such as WHS Acts and Regulations)
  • International and Australian Standards
  • Industry codes of practice
  • Client, contractor, and supply-chain expectations

By identifying these gaps, organisations gain a clear and evidence-based understanding of where systems fall short, are inconsistent, or are not fully implemented.

Strengthening Legal and Regulatory Compliance

One of the most compelling reasons to conduct a gap analysis is to ensure compliance with laws and regulations. Under WHS legislation, organisations have a primary duty of care to provide a safe working environment. Failure to comply can result in serious incidents, prosecutions, financial penalties, and reputational damage.

Similarly, environmental legislation imposes strict obligations regarding pollution control, waste management, and resource use, while quality requirements are often embedded in contractual and consumer protection frameworks.

A gap analysis helps organisations:

  • Identify areas of non-compliance before regulators do
  • Address outdated procedures that no longer align with current legislation
  • Demonstrate due diligence and proactive risk management

This proactive approach significantly reduces the likelihood of enforcement action and supports defensible decision-making if incidents occur.

Improving Risk Management and Performance

Effective risk management is central to WHS, quality, and environmental systems. Without a clear understanding of system gaps, risks may remain unrecognised or inadequately controlled.

A gap analysis enables organisations to:

  • Identify missing or ineffective risk controls
  • Highlight inconsistencies between documented procedures and actual practice
  • Detect areas where staff competency, training, or awareness is insufficient

By addressing these gaps, organisations can reduce workplace injuries, product or service failures, and environmental incidents. This leads to improved operational performance, reduced downtime, and lower costs associated with rework, claims, and remediation.

Supporting Certification and Integrated Management Systems

Many organisations seek or maintain certification to ISO standards as a way of demonstrating credibility and consistency. A gap analysis is often the first step in achieving certification or transitioning between standards (for example, upgrading from older versions of ISO standards).

For organisations operating integrated management systems—where WHS, quality, and environmental requirements are managed together—a gap analysis helps:

  • Identify duplication or conflicting processes
  • Streamline documentation and governance
  • Align objectives and performance measures across systems

This integration improves efficiency and ensures that compliance efforts support broader business goals rather than operating in silos.

Enhancing Governance and Leadership Oversight

Strong governance requires visibility over risks and controls. Boards and senior leaders are increasingly accountable for WHS and environmental outcomes, particularly in high-risk industries.

A structured gap analysis provides leadership with:

  • Clear, objective insights into system maturity
  • Prioritised actions based on risk and impact
  • Evidence to support strategic investment in safety, quality, and sustainability initiatives

This level of insight allows leaders to make informed decisions and demonstrates a genuine commitment to responsible corporate management.

Building a Culture of Continuous Improvement

Beyond compliance, gap analysis plays a key role in fostering a culture of continuous improvement. It encourages organisations to move beyond “minimum compliance” and focus on effectiveness, efficiency, and resilience.

When conducted regularly, a gap analysis:

  • Encourages open discussion about system weaknesses
  • Engages workers and managers in improvement initiatives
  • Tracks progress over time and measures the effectiveness of corrective actions

This continuous improvement mindset supports long-term sustainability and adaptability in a changing regulatory and business landscape.

Conclusion

Conducting a gap analysis of work health and safety, quality, and environmental management systems is not merely a compliance exercise—it is a strategic business imperative. It enables organisations to identify risks, meet legal obligations, improve performance, and strengthen governance.

By investing time and resources into a thorough gap analysis, companies position themselves to protect their people, deliver consistent quality, minimise environmental impact, and build trust with regulators, clients, and the broader community. Ultimately, a well-executed gap analysis supports safer, more efficient, and more sustainable business operations.

Get in touch with us and make conducting your gap analysis easier. Or better still, subscribe to Sherm Software and you will be able to see and rectify gaps as they arise.

New Workplace Exposure Limits: What’s Changing and Why It Matters

What are Workplace Exposure Limits (WEL)?

Workplace Exposure Limits (WEL) are the maximum concentrations of airborne contaminants (dust, fumes, vapours, gases, mists) that a person can be exposed to in the workplace without suffering serious or long-term harm.

Starting 1 December 2026, WEL will officially replace the current Workplace Exposure Standards (WES) in Australia. While the old WES already served as protective benchmarks, the shift to WEL is more than just a name change — it reinforces that these are limits that must not be exceeded, not simply best-practice standards.

Why the Change?

  1. Better Health Protection – The WES were reviewed against more up-to-date health evidence. Based on this, many exposure limits have been revised. Some have been lowered to reflect newer research, while others have been raised, and a number of previously unlisted substances are now included.
  2. International Alignment – Renaming “standards” to “limits” brings Australian WHS terminology more in line with international practice.
  3. Regulatory Clarity – Calling them limits underscores a stricter compliance requirement: they aren’t aspirational targets but enforceable boundaries.

What Exactly Is Changing?

Safe Work Australia has published a detailed list of WELs showing how each airborne contaminant will be affected. Here are the key types of changes to expect:

  • Adjustments to Existing Limits: Some substances will have lower or higher exposure thresholds.
  • New Substances Added: Certain airborne contaminants not previously subject to a limit will now be regulated.
  • Merged or Split Groups: For example, some chemical groups are being combined, others split to reflect different health impacts or particle behaviours.
  • Removal of Some Limits: There are airborne contaminants known as Non-Threshold Genotoxic Carcinogens (NTGCs). These are substances for which no “safe” exposure level can be reliably established. For those, no WEL will be assigned — so PCBUs must eliminate, substitute, or reduce exposure “as much as reasonably practicable.”
  • Types of Limits: There are three kinds of exposure limits in the WEL:
    • TWA (8-hour time-weighted average) — average exposure over a standard shift.
    • STEL (Short-Term Exposure Limit) — average for a short period, typically 15 minutes.
    • Peak Limitation — the maximum instantaneous exposure allowed, even for very short moments.

What Does This Mean for Employers (PCBUs) and Workers?

For Employers / PCBUs:

  • Risk Assessment – Begin reviewing which airborne contaminants you generate or use. Compare your current exposure data (or planned data) against the new WEL values.
  • Control Measures – Use the hierarchy of controls: try to eliminate or substitute harmful substances first, then use engineering controls (ventilation, isolation), administrative controls, and only then PPE / respiratory protection.
  • Monitoring – Air monitoring may need to be reviewed or redone under the new limits. Consider engaging an occupational hygienist to help design monitoring programs.
  • Training and Consultation – Inform and consult with workers about the coming changes. Review Safety Data Sheets (SDS) and talk through exposure risks and controls.
  • Health Surveillance – Depending on the substances, you may need to introduce or upgrade health monitoring for workers.
  • Regulatory Compliance – Ensure you understand how WEL will be implemented under your jurisdiction’s WHS laws.

For Workers:

  • Know Your Rights – You are entitled to understand the risks in your environment, what airborne contaminants you’re exposed to, and what the new limits will mean for you.
  • Use PPE Properly – If respiratory protective equipment (RPE) is required, make sure you know how to fit and use it correctly.
  • Ask Questions – If you’re unsure about exposure, speak to your safety rep or management. Ask if air monitoring has been done or is planned.
  • Stop Work If Necessary – If you believe exposure levels are unsafe, you can raise this concern.

Challenges and Considerations

  • Non-Threshold Carcinogens: For NTGCs (chemicals where there’s no safe threshold), compliance isn’t about meeting a numerical limit — it’s about eliminating or reducing risk as much as reasonably practicable.
  • Multiple Contaminant Exposure: In practice, workers may be exposed to more than one airborne contaminant. The combined (or interactive) effects may be more harmful than each on its own, so a holistic risk assessment is necessary.
  • Resource Constraints: Especially for small businesses, implementing more rigorous monitoring, bringing in occupational hygienists, or upgrading engineering controls can be a cost and resource challenge.
  • Transition Period Awareness: Until 30 November 2026, the old WES still apply. But businesses should not delay preparation.

Next Steps — How to Prepare

  1. Audit Your Current Exposure
    • List all airborne contaminants in use or generated in your workplace
    • Check current exposure levels (or plan monitoring)
    • Compare with the upcoming WEL values (once published)
  2. Engage Experts
    • Consider hiring an occupational hygienist or WHS consultant
    • Use their expertise to design control measures and exposure monitoring
  3. Update Risk Management Plans
    • Review your WHS risk register and update it for WEL risks
    • Revise safe work method statements (SWMS) or SOPs if needed
  4. Train Your Team
    • Run training on the new limits, on appropriate PPE, and on hazard recognition
    • Encourage consultation with workers — especially those working directly with the contaminants
  5. Health Monitoring
    • Where relevant, implement medical surveillance / health-check programs for workers exposed to airborne contaminants.
  6. Stay Informed
    • Subscribe to Safe Work Australia’s “Exposure Standards” mailing list for updates.
    • Check your regulator’s website for local guidance, as implementation details may vary by state / territory

Conclusion

The move to Workplace Exposure Limits (WEL) marks a major step forward for occupational health in Australia. By tightening and updating exposure thresholds, introducing new substances, and changing the language to reinforce these as non-negotiable limits, the transition strengthens protection for workers against airborne hazards.

But it’s not just a regulatory change — it’s a call to action. Employers need to assess, plan, control, monitor, and train. Workers need to stay informed, engage in safety discussions, and make sure protections are in place.

As we all know, time flies. 1 December 2026 seems far away, but there’s a lot to do prior to the implementation date, so the time to prepare is now.

Sherm Software can be a lifesaving tool for your workers and workplace. Sherm’s Registers module includes the Chemical Register which documents all chemicals used within the business, monitors SDS expiry with notification sent when renewal is required, and retains completed Risk Assessments uploaded as an attachment or Sherm gives you the ability to complete an Electronic Risk Assessment. Workers can access SDS on Sherm’s Mobile App.

Your SWMS’s and SOP’s are maintained in Sherm’s Documentation module making them available to workers at any time using the Mobile App.

Training on new limits, appropriate PPE, and on hazard recognition can be scheduled using Sherm’s Training and Competency module ensuring workers are informed and safe, and your obligations have been met.

Sherm’s People module ensures all Health Information is retained with the workers details where medical surveillance / health-check programs have been implemented, with notification sent when retesting is due.

Get in touch with us today and let Sherm help you.

Implementing Psychosocial Risk Controls: A National Strategy

Why a National Approach is Essential

Psychosocial hazards are now recognised in every Australian jurisdiction under WHS laws, with specific Codes of Practice and regulator guidance in place. While terminology and commencement dates vary between states and territories, the core duties are consistent:

  • Identify psychosocial hazards
  • Assess the associated risks
  • Implement effective control measures
  • Review and maintain those controls

A national strategy ensures multi-site organisations apply consistent processes, meet local legal requirements, and maintain a unified safety culture across all operations.

Key Principles for a National Strategy

Embed Psychosocial Risk into Existing WHS Systems

  • Integrate mental health hazard identification into current safety inspections, risk registers, and incident investigations.
  • Use a unified template for psychosocial risk assessments, adaptable to local needs.

Apply the Hierarchy of Controls

  • Prioritise eliminating hazards (e.g., redesigning work to avoid excessive demands).
  • Follow with substitution, engineering, administrative controls, and training — noting PPE is rarely applicable for psychosocial risks.

Use Evidence-Based Frameworks

  • Align controls with regulator-endorsed guidance (e.g., Safe Work Australia and state-specific Codes of Practice).
  • Incorporate recognised models to design safer work.

Build a Reporting and Feedback Culture

  • Provide confidential, accessible channels for workers to raise concerns.
  • Ensure managers are trained to recognise and respond to psychosocial hazards sensitively and constructively.

Monitor, Review, and Improve

  • Collect data from hazard reports, surveys, exit interviews, and absenteeism trends.
  • Review controls at scheduled intervals and after any incident or organisational change.

How SHERM Supports a National Rollout

  • Centralised Risk Management: One platform to log, assess, and control psychosocial hazards across all sites.
  • Custom Templates: Risk assessment forms mapped to each state’s Code of Practice while maintaining a consistent company-wide standard.
  • Training and Compliance Tracking: Automated reminders for mandatory psychosocial hazard awareness training.
  • Incident and Concern Reporting: Mobile and web-based reporting for early intervention.
  • Audit-Ready Evidence: Comprehensive records to satisfy any regulator, in any jurisdiction.

The Payoff

A coordinated national strategy not only ensures compliance in every state and territory, but also:

  • Reduces incidents linked to mental health harm
  • Improves employee engagement and retention
  • Strengthens organisational reputation as a mentally safe workplace

National Psychosocial Risk Control Strategy

A consistent approach to meeting mental health duties across Australia

National Compliance Snapshot

Jurisdiction Primary Legislation Key Psychosocial Duty Current Code of Practice/Guidance Commencement
QLD Work Health and Safety Act 2011 Identify, assess, control, and review psychosocial hazards Managing the Risk of Psychosocial Hazards at Work Code of Practice 2022 1 Apr 2023
NSW Work Health and Safety Act 2011 Manage psychosocial risks as WHS hazards Code of Practice: Managing Psychosocial Hazards at Work (2021) 1 Oct 2022
VIC Occupational Health and Safety Act 2004 Identify, assess and control psychosocial hazards (Regulation 2022) OHS Amendment (Psychological Health) Regulations 1 Sep 2022
WA Work Health and Safety Act 2020 Same duty of care for psychological and physical safety Code of Practice: Psychosocial Hazards in the Workplace (2022) 24 Dec 2022
SA Work Health and Safety Act 2012 Manage psychosocial hazards under general duty Code of Practice: Managing Psychosocial Hazards at Work (SA adopted) 1 Jul 2023
TAS Work Health and Safety Act 2012 Treat psychosocial hazards like other WHS risks Guidance: Psychosocial Hazards in the Workplace Ongoing
NT Work Health and Safety (National Uniform Legislation) Act 2011 Eliminate or minimise psychosocial risks so far as reasonably practicable Code of Practice: Managing Psychosocial Hazards at Work Ongoing
ACT Work Health and Safety Act 2011 Identify and control psychosocial hazards Code of Practice: Managing Psychosocial Hazards at Work Ongoing

National Control Strategies

Core Risk Control Principles (Applies in All States/Territories)

  • Eliminate hazards where possible (e.g., redesign roles to avoid excessive demands).
  • Engineering controls (e.g., improved rostering systems to manage workloads).
  • Administrative controls (e.g., clear policies, fair change management processes).
  • Training and support (e.g., leadership training in psychological safety, staff awareness sessions).
  • Ongoing monitoring (e.g., regular staff surveys, review of absenteeism and turnover data).

Example Risk Controls

  • Workload Management → Monitor workloads, redistribute tasks, and avoid prolonged excessive demands.
  • Clear Role Expectations → Maintain up-to-date job descriptions and ensure they are discussed during performance reviews.
  • Bullying and Harassment Prevention → Implement zero-tolerance policies and accessible reporting procedures.
  • Remote or Isolated Work Safety → Provide regular contact, mental health resources, and technological support.
  • Critical Incident Support → Offer employee assistance programs and structured post-incident debriefs.

National Implementation Tips

  1. Integrate into Existing WHS Systems — Build psychosocial hazard checks into current risk registers, inspections, and incident investigations.
  2. Use a Standardised Risk Assessment Template — Keep the same core format nationally, adjusting for state-specific guidance.
  3. Train Managers and Workers — Ensure leaders can recognise and respond appropriately to psychosocial hazards.
  4. Maintain an Evidence Trail — Record hazard identification, risk assessments, control measures, and review dates for audit readiness.
  5. Review Controls Regularly — Especially after incidents, organisational change, or workforce feedback.

With SHERM, your organisation can meet psychosocial hazard duties in every Australian jurisdiction — with one, consistent, audit-ready system.

Get in touch today and discover more.

Is RF EME the Next Emerging WHS Risk? Here’s Why You Should Pay Attention

In today’s tech-saturated world, Radiofrequency Electromagnetic Energy (RF EME) is everywhere—from mobile phone towers and Wi-Fi routers to smart meters and industrial antennas. While most regulatory bodies claim current exposure levels are safe, growing independent research suggests it’s time to look deeper.

At Sherm, we’re always thinking ahead for our clients. That’s why we’ve just released a new RF EME Awareness Procedure and Risk Assessment Template as part of our commitment to emerging risk management.

⚠️ The Science Isn’t Settled—But the Risk Is Real

Regulatory bodies like ARPANSA and ICNIRP base exposure limits on thermal effects (tissue heating). However, independent research—including the BioInitiative Report and studies published in peer-reviewed journals—highlights non-thermal biological effects such as:

  • Oxidative stress

  • Sleep disturbance

  • DNA damage

  • Neurological changes

  • Increased cancer risk

These effects have been observed at exposure levels well below current “safe” limits.

📋 What Sherm Clients Can Access Now

Our new RF EME document pack includes:

  • A practical RF EME Awareness Procedure aligned with WHS obligations

  • A ready-to-use Risk Assessment Template for evaluating site-based exposure

  • A contrast between ARPANSA/ICNIRP standards and precautionary guidelines recommended by the BioInitiative Report

These documents are perfect for organisations working near high-frequency zones or simply wanting to stay ahead of emerging compliance expectations.

🧭 Leading with Precaution

While there may be no official consensus yet, the principle of “better safe than sorry” has never been more relevant. Proactive management of RF EME exposure isn’t just smart risk governance—it’s responsible leadership in health and safety.

Ready to empower your workforce and strengthen your WHS compliance?

👉 Contact Sherm to learn more or request access to our RF EME documentation suite.