The Reality: Most Buildings Have Gaps
In most markets — and especially in Bangladesh — perfect compliance across all building systems is rare. A building that scores 60/100 against a comprehensive compliance assessment is not unusual. The professional response is not to pretend the gaps don't exist or to refuse to occupy the building — it's to document the gaps, assess the risks, create a remediation plan, and manage it systematically.
This article provides a framework for doing exactly that — turning a messy compliance reality into a managed, auditable, defensible position.
Gap Management Process
Step 1 — Comprehensive Gap Assessment
Before you can manage gaps, you need to know what they are. Commission assessments across key disciplines:
| Discipline | Assessment Type | Benchmark | Assessor |
|---|---|---|---|
| Structural | Rapid Visual Screening (FEMA 154) | BNBC 2020 Part 6 | Structural PE |
| Fire | Fire Risk Assessment (FRA) | BNBC Part 4 / NFPA | Fire protection engineer |
| Electrical | Electrical Safety Audit | BNBC Part 8 / IEC 60364 | Electrical engineer |
| Mechanical | HVAC/Ventilation Assessment | ASHRAE 62.1 / 55 | Mechanical engineer |
| Lifts | Independent Lift Audit | EN 81 / ASME A17.1 | Lift consultant |
| Accessibility | Accessibility Audit | BNBC Part 2 / ADA | Accessibility consultant |
Step 2 — Gap Register
Every gap identified goes into a structured register:
| Field | Description |
|---|---|
| Gap ID | Unique reference (e.g., FIRE-001, ELEC-003) |
| Discipline | Structural / Fire / Electrical / Mechanical / Lift / Accessibility |
| Description | Clear description of the gap |
| Standard Reference | Which standard/code section is not met |
| Risk Rating | Critical / High / Medium / Low |
| Current Status | Open / In Progress / Closed / Accepted Risk |
| Remediation Action | What needs to be done |
| Responsibility | Landlord / Tenant / Shared |
| Estimated Cost | Budget estimate for remediation |
| Target Date | When remediation should be completed |
| Interim Control | What's being done NOW while remediation is pending |
Step 3 — Risk-Based Prioritisation
| Priority | Risk Level | Timeline | Examples |
|---|---|---|---|
| P1 — Immediate | Life safety risk | 0-30 days | Locked fire exits, no fire alarm, dangerous electrical, structural distress |
| P2 — Short Term | Significant compliance gap | 1-6 months | No sprinklers (high-rise), inadequate earthing, exit stair deficiencies |
| P3 — Medium Term | Code compliance gap | 6-18 months | Accessibility improvements, energy efficiency, ventilation upgrade |
| P4 — Long Term | Best practice gap | 18+ months / next lease | Full NFPA 13 sprinklers, comprehensive BMS, LEED certification |
Step 4 — Interim Controls
While remediation is pending, implement interim controls to reduce risk:
| Gap | Interim Control | Cost | Effectiveness |
|---|---|---|---|
| No fire alarm | Portable battery-powered smoke detectors on every floor | Low | Moderate — detection only, no central monitoring |
| No sprinklers | Additional fire extinguishers, fire warden training, enhanced evacuation drills | Low-Medium | Limited — doesn't replace suppression |
| Poor earthing | Portable RCDs on critical circuits, earth testing schedule | Low | Moderate — protects specific circuits |
| Single staircase | Enhanced evacuation planning, fire warden on every floor, external ladder access | Low | Low — fundamental life safety gap remains |
| No emergency lighting | Battery-powered LED emergency lights | Low | Good — direct solution |
Step 5 — Management Reporting
The gap register becomes a management reporting tool. Monthly/quarterly reports should show:
- Total gaps: Open / In Progress / Closed / Accepted Risk
- By priority: P1 (how many? all addressed?), P2, P3, P4
- Remediation progress: % closed vs plan, delays and reasons
- Cost tracking: Budget vs actual spend on remediation
- Risk trend: Is overall risk reducing over time?
Accepted Risk — When You Can't Fix Everything
Some gaps cannot be remediated without rebuilding the building. When a gap is accepted rather than fixed:
- Document the risk clearly — what could happen and what's the consequence
- Implement maximum interim controls
- Get management sign-off — documented acceptance at appropriate authority level
- Set review frequency — accepted risks must be reviewed, not forgotten
- Include in lease strategy — plan to address at next lease renewal or relocation
Making It Audit-Ready
When a global audit team visits, they want to see:
- You know your gaps (gap register exists and is comprehensive)
- You've assessed the risk (each gap has a risk rating)
- You have a plan (remediation actions with dates and owners)
- You're making progress (closure trend is positive)
- You've managed the risk in the meantime (interim controls documented)
- Management has approved accepted risks (sign-off documented)
An auditor who finds a building at 60% compliance with a comprehensive gap register, remediation plan, and documented interim controls will give you a much better rating than an auditor who finds a building at 80% compliance with no documentation and no plan for the remaining 20%.
References
Insights & Guidance
- Most buildings have compliance gaps — the professional response is systematic gap management, not denial or avoidance.
- Gap register: unique ID, description, standard reference, risk rating, remediation action, responsibility, cost, target date, interim control.
- Prioritise by life safety risk: P1 (immediate, 0-30 days) through P4 (long-term, next lease).
- Interim controls reduce risk while remediation is pending — documented interim controls are essential.
- Auditors value documented gap management over undocumented higher compliance. A 60% building with a plan beats an 80% building without one.
Compliance gap management is the bridge between the building you have and the building you need. It turns an uncomfortable reality into a managed, auditable, defensible position — which is what professional building management looks like in markets where perfect compliance is rare.
- Gap denial — ignoring gaps doesn't eliminate risk, it just makes it unmanaged.
- Paper compliance — having a gap register that's never updated or acted upon.
- No interim controls — waiting for remediation without managing current risk.
- Comprehensive gap register (structured spreadsheet or system)
- Remediation plan with timeline, cost, and responsibilities
- Interim control documentation
- Management sign-off on accepted risks
- Monthly/quarterly progress reports
- Is the gap register current and maintained?
- Are P1 gaps all addressed or controlled?
- Is remediation progressing per plan?
- How many open P1/P2 gaps are there right now?
- What interim controls are in place for critical gaps?
- When was the last gap register review?
- Gap assessment — discipline-specific engineers and consultants as listed above.
- Risk management framework — ISO 31000 trained risk consultant.
- Audit preparation — experienced FM/CRE compliance consultant.