The TRIR trend and the OSHA logs are curated by the seller and backward-looking by design. I assess what you’re actually buying: the deferred capex, the single points of failure, and the exposures that surface in month seven of your hold.
Standard diligence checks whether safety documents exist. It rarely checks whether they describe the operation you’re buying. A clean recordable rate can coexist with an unguarded palletizer, a lockout program that lives in one maintenance lead’s head, and a dust hazard analysis citing a standard that no longer exists. Reps and warranties transfer legal recourse — they do not transfer operational risk.
A focused pass on the data room plus targeted questions for management — what’s missing matters more than what’s there. Scoped to deal timelines, not audit timelines.
High-energy exposures first: hazardous energy, mobile equipment, falls, confined spaces. I’ve run plants — I know what deferred maintenance looks like when it’s dressed up for a sale.
A sequenced exposure map with capex estimates, the mod trajectory, and the two or three systems that must exist by month twelve — built to slot into your value creation plan.
A concise exposure memo written in deal language: what’s real, what it costs to fix, what it means for the model, and what should move to the purchase agreement. Not a 200-page compliance audit nobody reads — the document your investment committee actually needs.
The same discipline applies to the E: permits matched against actual operations, unpermitted emission units flagged, waste practices and generator status verified, and storage measured against SPCC and reporting thresholds — run by our environmental practice, and coordinated with (never substituting for) the Phase I ESA your lender or counsel requires.
Pre-close reviews are scoped to deal timelines — typically days, not weeks, depending on data room access and whether a site visit is possible before close. Post-close exposure mapping runs deeper across the first 90 days of ownership.
A compliance audit checks conformance against regulations line by line. Due diligence answers a different question: what does this operation’s risk actually cost, and how does it affect the deal? The output is an exposure memo for an investment committee, not a findings list for a safety office.
Yes. Brokers, carriers, and lenders are often the first to spot an EHS problem in a deal, and I regularly work alongside them to translate loss history and mod trajectory into deal terms.
Diligence conversations are confidential and scoped to your timeline. Bring the CIM question you can’t answer.
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