When ships reached the end of their operational life, they are required to be dismantled in a safe and environmentally friendly manner. However, current ship recycling process in Indonesia is not compliant with the standard of existing rules and is not environmentally friendly and dangerous to the safety of the workers. In this paper, a comprehensive gap analysis was conducted through the comparison of the current process with the standard of international regulations from health and safety perspective. The analysis is based on the expert judgement technique that combined the field observation and questionnaire to assess the current process as well as to identify the process related gaps compared to the current regulations. This has been achieved through these major steps: (1) Identification of ship recycling process, (2) Established an expert team, (3) Development of ideal process (4) Field observation (5) Development of observed process flow (6) Identify the gap.