EHS Compliance Gaps
As 2025 unfolds, the regulatory landscape for Environmental, Health & Safety (EHS) is tightening—and small to mid-sized businesses (SMBs) are feeling the pressure. With OSHA enforcement increasing, EPA penalties rising, and new digital recordkeeping expectations becoming the norm, even well-intentioned companies are finding themselves out of compliance.
The problem isn’t a lack of care.
It’s a lack of time, expertise, and proactive structure—especially for organizations without full-time EHS leadership.
In this report, we break down the top EHS compliance gaps SMBs must address in 2025, why they occur, and how companies can fix them before they lead to fines, incidents, or operational disruption.
1. Outdated or Incomplete Safety Training Programs
Training is the backbone of compliance, yet it remains one of the most common—and costly—gaps across SMBs.
In 2025, OSHA continues to emphasize “training validity,” meaning training must be:
- Task-specific
- Documented
- Frequent enough to remain effective
- Delivered in a language and format employees understand
Where SMBs fall short
- Expired forklift certifications
- Incomplete PPE training
- Supervisors trained, but not frontline employees
- Onboarding missing safety elements
- No refresher cycles established
Without structured scheduling, tracking, and documentation, training quickly becomes an audit exposure.
How to fix it
- Implement a digital training tracker
- Build a training matrix for every job role
- Schedule annual and task-specific refreshers
- Use toolbox talks to fill daily gaps
A fractional EHS leader can audit your current training system and build a sustainable program.
2. Poor Documentation & Recordkeeping
OSHA, EPA, and state regulators assume:
“If it isn’t documented, it didn’t happen.”
And in 2025, documentation expectations are higher than ever.
Common documentation gaps
- Missing safety meeting records
- No written programs for LOTO, HazCom, Respiratory Protection
- Incomplete incident investigation forms
- No SDS management system
- Expired or non-existent permits
For many SMBs, paperwork exists—but it’s scattered across emails, spreadsheets, or filing cabinets.
Why this matters
During an inspection, missing documentation can immediately escalate into a citation or fine—even when actual safety practices are strong.
How to fix it
- Centralize all documents in a shared, digital EHS hub
- Conduct quarterly documentation audits
- Standardize forms, templates, and naming conventions
- Use dashboards to track expirations and renewals
Streamlining documentation reduces regulatory risk and improves operational clarity.
3. Incomplete or Outdated Hazard Assessments
Hazard assessments should evolve alongside your operations, yet most SMBs haven’t completed a full assessment in years.
Common issues
- Hazard assessments not tied to job tasks
- No site-specific risk scoring
- No updates after new equipment or processes
- PPE requirements based on assumptions, not assessment
- Confined space classifications not documented
Why this is a major 2025 risk
OSHA is putting more focus on risk-based enforcement, meaning outdated assessments can be a liability—especially in high-risk industries such as manufacturing, construction, and logistics.
How to fix it
- Conduct annual site-wide hazard assessments
- Reassess anytime equipment or processes change
- Update PPE requirements based on data
- Train supervisors on job hazard analysis (JHA)
4. Weak Contractor Management Programs
Contractors often introduce risk—but many SMBs lack a structured oversight program.
Common contractor compliance gaps
- No pre-qualification process
- Missing proof of insurance or safety records
- No contractor orientation
- No supervision or spot-checks during work
- No post-work evaluation
In 2025, these gaps are becoming more costly as companies rely more on outsourced labor.
How to fix it
- Develop a contractor onboarding checklist
- Require safety documentation before site access
- Provide site-specific orientation
- Implement a permit-to-work or visitor control system
- Conduct periodic field audits
5. Environmental Permitting & Reporting Lapses
Environmental compliance is increasing in complexity, catching many SMBs off guard.
Common gaps
- Expired stormwater permits
- Missing SPCC plans
- Inaccurate emissions or waste reporting
- Lack of sampling or monitoring
- Poor documentation of environmental controls
Why this matters in 2025
EPA enforcement for small facilities has risen sharply, especially in manufacturing, logistics, and energy.
How to fix it
- Conduct an environmental compliance audit
- Maintain a permit renewal calendar
- Document every environmental inspection
- Train supervisors on environmental responsibilities
6. Safety Culture Breakdown
Even with strong programs on paper, SMBs often lack consistency in the field.
Warning signs of weak safety culture
- Supervisors not reinforcing procedures
- PPE non-compliance increasing
- Employees hesitant to report hazards
- Shortcuts becoming normal practice
Why this gap matters
Culture determines whether your safety systems succeed or fail. Weak culture is one of the top contributors to preventable incidents.
How to fix it
- Launch a simple reporting system
- Conduct weekly leadership safety walks
- Recognize safe behavior
- Give supervisors safety leadership coaching
7. No Dedicated EHS Leadership or Oversight
This is the biggest gap of all.
Most SMBs simply don’t have the budget for a full-time EHS manager—so safety becomes a side responsibility for HR, operations, or supervisors.
The result
- Reactive safety
- Inconsistent oversight
- Missed deadlines
- No accountability
- No strategic plan
Fractional EHS is the modern solution
2025 has seen a major rise in fractional EHS leadership, allowing SMBs to access:
- Certified EHS expertise
- Regulatory guidance
- Program development
- Training support
- Audit readiness
- Environmental compliance oversight
—without hiring a full-time staff member.
Conclusion
EHS compliance in 2025 is more demanding, more complex, and more closely monitored than ever. For SMBs—especially in manufacturing, construction, logistics, energy, and industrial services—the risks of falling behind are real.
But with the right leadership, structure, and proactive systems, these gaps can be closed quickly and cost-effectively.
If your business is growing—or struggling with limited internal resources—fractional EHS support gives you the expertise you need, without the full-time expense.
