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Gap Closure List — Achilles UVDB B2

As at: 24 April 2026 Audit expected: June 2026 (date TBC) Total open items: 15 gaps + 3 critical pre-existing debts

Downloadable

Download as Excel — filterable tracker, status column, conditional formatting by priority.

How this list works

Each gap is classified by priority:

Priority Meaning
P1 — Must close Blocking or close to blocking. Auditor will expect evidence. Failing here risks non-conformance.
P2 — Strongly advised Not technically blocking but significantly strengthens the audit. Often closable in a few hours.
P3 — Acceptable to disclose Legitimate N/A or a small enough gap that a documented "plan in place" answer is acceptable.

Each gap has an owner, a target date and an estimated effort to close.

P1 — Must close before audit

These are the gap items where the auditor will most likely raise a non-conformance or observation if they remain open.

# Gap B2 ref Owner Target Est. effort Closure action
1 32 Supplier Annual Reviews (SARs) all overdue (Sept 2025) 1.12.2 Leanne Mason 31/05/2026 ~32 hrs over 2 weeks Bulk email template (drafted separately); chase all 32 suppliers; capture responses in SAR docs on IMS. This is the single biggest audit risk.
2 BCP test / review records 1.3.1 Sean Ashton 31/05/2026 2 hrs Run a short desktop exercise with Aaron + Leanne. Document: scenario (e.g. office fire + critical IT loss), response actions, issues identified, action register. Attach as BCP appendix.
3 Senior management safety tours / inspections ✓ 1.7.3 Aaron Mason Closed 04/05/2026 Done Director Site-Tour Programme live — FORM_DST_01 template, first record 28/04/2026 (Westleigh Road, Aaron Mason). Quarterly recurrence on KPI B3.
4 Toolbox talk programme + records ✓ 1.7.6 Jason May Closed 04/05/2026 (programme); 31/05/2026 (3 deliveries) 3 hrs 12-month TBT programme live with 3 priority topic briefs (excavation / HAVS / COSHH-fuels) ready to deliver weeks of 12/05, 19/05, 26/05 2026. Attendance template in same page.
5 Carbon footprint recording 1.11.1 Sean Ashton 31/05/2026 4-6 hrs Produce a Scope 1 & 2 baseline statement from 2025 fuel (diesel, petrol, 2-stroke) and electricity bills. Even a first-cut baseline with caveats is enough to evidence "recording in place".
6 3 expired statutory training certificates 1.5.3 Leanne Mason 31/05/2026 External course bookings Jason May Fire Marshal (EXP 15/08/2025), Leanne Mason Fire Marshal (EXP 19/09/2025), Leanne Mason Emergency First Aid (EXP 30/10/2025). Book replacement courses immediately. Also check Aaron Mason's Fire Marshal cert — not currently on file.

P1 total estimated effort: ~42 hours (of which 32 is the SAR-chase workload for Leanne; the rest is Sean / Jason working time ~10 hrs).

P2 — Strongly advised to close

These materially strengthen the audit but a documented forward plan would be acceptable as a minimum.

# Gap B2 ref Owner Target Est. effort Closure action
7 IT Security Policy ✓ 1.2.3 Sean Ashton Closed 04/05/2026 Done POL_HSQE_30 live — practical SME-scaled policy (access/MFA, cloud/backup, email, BYOD, incident response with UK GDPR 72-hr pathway). Deliberately not an ISMS — explicit rationale in policy body.
8 Right-to-Work procedure ✓ 1.4.3 Leanne Mason Closed 04/05/2026 Done PROC_R2W_01 live — operational steps, share-code verification, retention DofE+2yrs, annual sweep documented.
9 Permit to Work template (generic) ✓ 1.7.6 Sean Ashton Closed 04/05/2026 Done FORM_PTW_01 live — single template, three activity sections (excavation/hot-work/confined-space), close-out + 60-min hot-work fire-watch capture.
10 Signed PPE register 1.7.7 Leanne Mason 15/05/2026 1 hr Consolidate existing HS_FM_11 issue forms into a single signed Excel register per person per item.
11 Fatigue Risk Assessment ✓ 1.6.1 Sean Ashton Closed 04/05/2026 Done RA_HO_18 live — 7 hazards mapped (driver fatigue, on-call rotation, HAVS interaction, cognitive fatigue, lone-worker, overnight, manager fatigue). APP_07 hazards register updated to include HO-18.
12 Mental Health policy ✓ 1.8.1 Sean Ashton Closed 04/05/2026 Done POL_HSQE_29 live — MHFA cover, signposting routes (incl. Samaritans 116 123), reasonable adjustments, EAP-decision pathway (Aaron's #13).
13 Employee Assistance Programme (EAP) 1.8.1 Aaron Mason 15/05/2026 Commercial decision + ~1 hr to document Option A: enrol in a low-cost EAP (Health Assured / Vitality / Hospital Saturday Fund — approx £5-£15 per employee per month). Option B: document a rationale for not having one, alongside MHFA + OH procedures.
14 Sustainability report + explicit targets ✓ 1.11.1 Aaron Mason Closed 04/05/2026 Done Sustainability Note 2025 live — 1-pager covering waste >80% diversion, fleet telematics, community/CSR, PR24 alignment-led commitment, 2026–27 priorities. Pairs with 2025 carbon baseline (#5, in train).
15 Recycling initiatives write-up ✓ 1.10.4 Aaron Mason Closed 04/05/2026 Done Recycling Initiatives note live — 10 streams documented with carriers, evidence trail and 2026–27 improvement plan.

P2 total estimated effort: ~17 hours (mostly Sean on policy drafting + Leanne on HR admin).

P3 — Acceptable to disclose

These can remain open with a documented rationale. The auditor will accept them provided the position is considered and written down.

# Item B2 ref Position
16 FORS membership 1.1.4 Not held. Monitoring DVSA Earned Recognition for potential application — documented in APP_10 L52a and APP_05 R-21. Disclose to auditor.
17 Quality plan / Inspection & Test Plan 1.2.2 Not used as standalone documents. Quality requirements embedded in contract-specific MS + RAMS. Disclose. Consider producing a generic ITP template post-audit (low effort).
18 ISO 27001 certification 1.2.3 Not held. AMWS is small; IT security will be delivered via new IT Security Policy (item 7) + external IT support. Disclose with forward look in APP_05 O-02.
19 Design Risk Assessment 1.7.4 AMWS does not undertake design work. ISO 9001:2015 Clause 8.3 formally excluded in IMS Manual (Section 2.2). Cite the exclusion to auditor.
20 CFSI (Counterfeit / Fraudulent / Suspect Items) 1.13.1 Nuclear-industry only. AMWS does not work in nuclear. N/A.
21 SIA security licences 1.9.1 No security personnel employed. N/A.
22 Site security arrangements (fixed sites) 1.9.1 Work is temporary / public-highway based; client-site security arrangements on live-main work. Document as a short paragraph so the auditor sees it's a considered position.
23 FSC certificates for timber 1.13.2 Limited timber use; shoring boards from UK builders' merchants. Request FSC certificates from major suppliers (Jewson, etc.) for the supplier file before audit.

Summary

Priority Items Aggregate effort (Sean / Jason) Aggregate effort (Leanne) Aggregate effort (Aaron)
P1 — Must close 6 10 hrs 32 hrs (SARs) + course bookings 1 hr + attendance at desktop exercise
P2 — Strongly advised 9 12 hrs 2 hrs 1-2 hrs + EAP decision
P3 — Acceptable to disclose 8 Nil (document current position) — —
TOTAL 23 ~22 hrs ~34 hrs ~3 hrs

Hour budget reconciliation

Sean's 2026 compliance plan has 10 hours in the 7.4 Ad-hoc / Director Support bucket. The Achilles prep consumes approximately 22 hours of consultancy time (closing P1 items 2, 3, 4, 5 + P2 items 7, 9, 11, 12). This is ~12 hours of overspend against plan.

Mitigation options:

  1. Reshuffle — pull forward part of item 2.2 SOP review & update (June-August) into May; the permit-to-work template and fatigue RA work is effectively SOP drafting that would happen anyway.
  2. Accept overspend — raise as a variation at the May check-in with Aaron; recover in Q3 if the October Surveillance 2 runs smoothly.
  3. Narrow scope — accept some P2 items as P3 (e.g. Mental Health policy, IT Security Policy written post-audit with forward plan disclosed). Reduces consultancy time to ~12 hrs but gives the auditor more to raise.

Sean's recommendation: Option 1 — the SOP work needs doing anyway and the permit-to-work + fatigue RA are useful SOP-equivalents.