WHS Gap Analysis and Governance Review

An independent WHS review is often requested when there is a need for better visibility into how WHS processes operate in practice.

This commonly arises in situations such as:

• Before or following a visit from a regulator, an audit, or client scrutiny.

• Shortly after a serious incident or an emerging safety concern.

•  When a board or audit committee has requested independent confirmation.

• When existing WHS processes have not been independently reviewed in some time.

• When preparing for ISO certification, a government tender, or a similar requirement.

• When WHS documentation exists, but confidence in its accuracy and currency is low.

• When internal WHS capability is limited, an independent perspective is required to inform next steps.

• When planning a new site, operation, or significant change to work arrangements.

• When undertaking an organisational restructure or reviewing workforce arrangements.

• When senior leadership requires an independent understanding of the organisation’s current WHS position to inform strategic planning.

• When the organisation is seeking to lift WHS maturity as part of broader business improvement.

These situations often reflect underlying questions that are not easily answered through internal reporting alone, such as:

• How well-positioned are our WHS systems to withstand regulatory or client scrutiny if required?

• Do our documented processes accurately reflect how work is actually performed?

• Do we have a reliable understanding of our current WHS position across the organisation?

In these circumstances, independent examination helps clarify the factual position and identify what leadership can reasonably rely on.

A WHS Review provides a structured, point-in-time assessment of how WHS systems are governed and operate in practice, including documentation, operational practices, and oversight mechanisms.

Findings are translated into practical and prioritised recommendations, supporting leaders to understand where attention is required, what action is proportionate, and how due diligence is exercised in practice.

Organisations may choose between different levels of review depending on the depth of insight required. Some organisations need an initial snapshot of key WHS documentation. Others require a broader desktop assessment or a detailed WHS Gap Analysis and Governance Review.

Organisational Risk Consulting offers three structured review models, each tailored to the organisation’s context and designed to identify governance concerns and areas for further consideration.

A brief desktop review providing an initial overview of key WHS documentation and identifying areas that may warrant further attention.

The Snapshot includes:

• Review of up to 80 pages of WHS documentation (or equivalent, including large spreadsheets or registers).

• Regulatory and standards alignment: Observations on whether documentation appears to align with applicable WHS legislative requirements and, where relevant, key provisions of ISO 45001, based on professional experience and judgement. This does not constitute legal advice.

• A risk-based findings table to support prioritisation.

• A concise written summary identifying key themes for further consideration.

This Snapshot suits organisations seeking a quick overview of key WHS documents before considering a broader review.

A detailed desktop review assessing WHS documentation across the system in greater depth and identifying issues that may warrant further attention.

The Review includes:

• Review of over 80 pages of WHS documentation (or equivalent, including large      spreadsheets or registers)

• Comprehensive analysis of the WHS documentation provided.

• Regulatory and standards alignment: Assessment of whether documentation aligns with applicable WHS legislative requirements and, where relevant, key provisions of ISO 45001 and ISO 45003, based on professional experience and judgement. This does not constitute legal advice.

• Commentary on potential system issues.

• Practical recommendations for strengthening the WHS system.

• A written report outlining findings and improvement areas.

This Review is based solely on the documentation provided and does not include operational observations, workforce consultation, or verification of how the documented arrangements are implemented in practice.

It suits organisations seeking a detailed, system-wide documentation assessment before considering a broader WHS Gap Analysis and Governance Review.

A detailed review assessing WHS documentation, governance arrangements and how WHS systems operate in practice across the organisation.

The Detailed Review includes:

• Assessment of all relevant WHS documentation, governance arrangements and operational practices.

• Regulatory and standards alignment: Detailed assessment of how WHS arrangements align with applicable legislative requirements and, where relevant, ISO 45001 and ISO 45003, informed by operational observations and professional experience and judgement. This does not constitute legal advice.

• Operational observations may include discussions with personnel, the review of photographs or recorded video, live video walkthroughs, or in-person observations where required.

• Assessment of leadership oversight and due diligence arrangements.

• Evidence-based findings and prioritised recommendations.

• A written report outlining findings, areas of exposure and practical improvement opportunities.

This Detailed Review suits organisations seeking a comprehensive understanding of how WHS systems function in practice and where governance attention may be required.

A WHS Review provides senior leaders with independent insight that extends beyond documentation and checklist-based compliance. The review focuses on how WHS processes support effective governance and risk oversight in practice.  

This includes: 

• Decision-ready insight: Clear, executive-level reporting that supports informed leadership decisions and oversight of WHS risk. 

• Governance oversight: How WHS systems, roles and controls operate in practice, supporting accountability and due diligence.

• Strategic readiness: Preparedness for regulator engagement, audits, stakeholder review, and tender submissions, with priority risks and exposures clearly identified.

• ISO alignment (optional): Consideration of the key elements of ISO 45001 and ISO 45003 to assist organisations in understanding their level of alignment with recognised best-practice standards.

• Follow-up review (optional): Visibility of progress over time, where organisations choose to re-engage. 

Many organisations seek confidence not only in their overall WHS approach, but in how their systems may be interpreted under legal or regulatory scrutiny.

A WHS Review can place particular emphasis on:

• Regulatory scrutiny: Whether WHS documentation and records are likely to raise concern if tested under regulator or client scrutiny.

• Internal investigations: Reviewing whether investigation processes are sufficiently thorough, factual, and support due diligence and organisational learning. 

• System documentation: Identifying gaps or weaknesses in policies, procedures, and records, with recommendations to improve alignment with WHS Acts, Regulations, and relevant industry standards.

This approach draws on our combined WHS, investigative, and legal background to identify areas of exposure and support informed decision-making.

Organisational Risk Consulting offers a unique combination of expertise that strengthens confidence in every WHS Review:

• Legal insight: Legal and regulatory understanding, informed by experience in personal injury law and the WHS profession, informs how WHS systems may be interpreted under regulatory or stakeholder scrutiny. 

• Investigative experience: Licensed factual investigation capability, supporting independent, evidence-based reviews that enhance accountability and transparency.
   
• WHS leadership experience: Extensive experience within senior WHS roles in multiple sectors provides insight into both governance requirements and operational realities. 

• Independent perspective: Confidential, objective assessments that highlight strengths, identify areas of exposure, and support informed decision making.

The WHS Gap Analysis and Governance Review follows a structured process aligned to organisational context and leadership priorities.

The process typically includes:

1. Scoping discussions
Confirm organisational context, governance arrangements, leadership priorities and areas of focus so the review addresses matters most relevant to oversight and decision-making.

2. Information gathering
Collection and review of relevant information, including WHS documentation, governance arrangements and operational practices. This may include a desktop review and operational observations. Observations may involve discussions with personnel, review of photographs or recorded video, live video walkthroughs of work areas, or in-person observation where required.

3. Analysis of Information
Assessment of available information against applicable WHS obligations and selected ISO elements where relevant. The analysis is evidence-based and applies professional judgement to identify areas of strength, gaps and potential exposure.

4. Reporting and recommendations
Preparation of a report setting out findings, including strengths, areas of exposure and practical improvement opportunities. Recommendations are prioritised based on risk and potential impact on leadership oversight. 

5. Optional further engagement
Further engagement may be considered where this aligns with organisational needs, including follow-up review or targeted support on priority areas.