Last Updated on December 26, 2025 by Melissa Lazaro

Why an ISO 45001 Gap-Analysis Checklist Is the Smartest First Step

Here’s what I’ve noticed over the years.

Most organizations don’t fail ISO 45001 audits because they ignore safety.
They fail because they don’t know where the gaps are until the auditor points them out.

And by then, it’s too late.

An ISO 45001 gap-analysis checklist gives you clarity early.
It shows what’s working.
What’s missing.
And what needs attention before certification pressure kicks in.

In my experience, teams that start with a proper gap analysis feel more confident, move faster, and spend less fixing surprises later.

This guide walks you through how to use a practical ISO 45001 gap-analysis checklist—the same way we use it with clients preparing for certification.

ISO 45001 Gap Analysis Explained: What Auditors Expect to See

Let’s clear something up first.

A gap analysis is not an internal audit.
It’s a readiness check.

Auditors don’t expect perfection at this stage.
They expect honesty and structure.

A good ISO 45001 gap analysis checks:

• Whether required processes exist
• Whether they’re implemented
• Whether there’s evidence to support them

This matters because certification bodies often ask how you planned your implementation.
A documented gap analysis shows you took a systematic approach.

Pro tip:
Document gaps clearly, even uncomfortable ones. Auditors trust transparency more than last-minute fixes.

Common mistake:
Turning the gap analysis into a tick-box exercise without verifying real practices.

ISO 45001 Clause-by-Clause Gap-Analysis Checklist Structure

Now that we covered the purpose, let’s talk structure.

The most effective gap-analysis checklist follows ISO 45001 clause by clause.
That makes findings easier to convert into action plans later.

A typical checklist covers:

• Context of the organization
• Leadership and worker participation
• Planning and risk management
• Support and competence
• Operational controls
• Performance evaluation
• Improvement

I’ve seen teams struggle when they skip clause mapping.
Corrective actions become messy.
Responsibilities get unclear.

Pro tip:
Link each gap to the exact clause. It simplifies corrective action tracking.

Common pitfall:
Identifying gaps without noting what evidence is missing.

ISO 45001 Leadership & Worker Participation Gap-Analysis Checks

This is where many organizations think they’re strong—and then realize they’re not.

Leadership and worker participation aren’t just policies.
Auditors look for proof of involvement.

Your gap-analysis checklist should verify:

• Leadership accountability for OH&S
• Worker consultation processes
• Evidence of worker participation in risk assessments
• Awareness of the OH&S policy

I once worked with a client who had excellent documentation.
But when workers were interviewed, they didn’t know how they were consulted.

That became a major gap.

Pro tip:
Interview both leadership and workers during the gap analysis.

Common mistake:
Assuming policies alone demonstrate commitment.

ISO 45001 Risk Assessment & Planning Gap-Analysis Checklist

This section deserves time and attention.

Hazard identification and risk assessment sit at the heart of ISO 45001.
Auditors always dig deep here.

Your checklist should assess:

• How hazards are identified
• How OH&S risks and opportunities are evaluated
• Whether legal and other requirements are identified and updated
• How planning actions are documented and reviewed

In my experience, outdated risk registers are one of the most common findings.

Operations change.
Processes evolve.
Risk assessments must keep up.

Pro tip:
Check whether risk assessments reflect current operations—not last year’s reality.

Common pitfall:
Using generic risk templates with no site-specific detail.

ISO 45001 Operational Control & Support Gap-Analysis Checks

This is where theory meets practice.

Operational control gaps usually show up in:

• Inconsistent procedures
• Poor training records
• Weak communication
• Uncontrolled documents

Your checklist should confirm:

• Procedures exist and are followed
• Workers are competent and trained
• Documents are controlled and accessible
• Communication channels are defined and used

Here’s something I tell clients often:
If a procedure sits in a folder nobody opens, it’s a gap.

Pro tip:
Ask workers how they actually perform tasks. Compare that to documented procedures.

Common mistake:
Over-documenting and under-implementing.

ISO 45001 Performance Evaluation & Improvement Gap-Analysis Checklist

This section shows whether your system is alive—or just installed.

A proper gap analysis checks:

• OH&S performance monitoring
• Incident investigation processes
• Internal audit planning
• Management review effectiveness
• Corrective action follow-up

I’ve seen organizations conduct internal audits just to “tick the box.”
Auditors see through that quickly.

Pro tip:
Use real incidents and near-misses as gap-analysis inputs.

Common pitfall:
Treating improvement as reactive instead of planned.

FAQs – ISO 45001 Gap-Analysis Checklist Questions Answered

When should an ISO 45001 gap analysis be done?

Ideally at the very start of implementation. It’s also useful before certification or during system reviews.

Who should perform the ISO 45001 gap analysis?

Internal teams can do it, but external reviewers often spot blind spots internal teams miss.

How detailed should the checklist be?

Detailed enough to identify real gaps—but not so detailed that it becomes a full audit.

Conclusion – Use the ISO 45001 Gap-Analysis Checklist to Stay in Control

Here’s the bottom line.

ISO 45001 audits shouldn’t feel like surprises.
A strong gap-analysis checklist gives you control early.

It helps you:

• Focus on the right priorities
• Plan corrective actions properly
• Enter certification audits with confidence

In my experience, organizations that invest time in gap analysis save far more time later.

Your next step is simple.
Use a structured ISO 45001 gap-analysis checklist—or get expert help to interpret the results and turn them into a clear action plan.

That choice alone often determines how smooth your certification journey will be.