Health & Safety Insights

Three industries still face greater odds of an OSHA visit! That’s because the agency relaunched an inspection program nationwide that targets the following sectors through July 2031, unless extended:

• Warehousing and distribution operations,
• Mail processing and distribution centers, and
• Parcel delivery and courier services

OSHA explains that federal data show injury and illness rates (with days away, restricted, or transferred) for these industries continue to be higher than in private industry overall and, in some cases, over two to four times the rate of private industry!

You cannot wait for OSHA’s knock on the door to begin preparing for the inspection and ensuring compliance. Take steps now to meet your OSHA obligations.

 

Background

The revised National Emphasis Program (NEP) on Warehousing and Distribution Center Operations (CPL 03-00-026) took effect July 31, 2026. It is one of only 12 targeting programs for the agency. NEPs are enforcement programs that concentrate the agency’s inspection and outreach efforts on specific hazards or high-hazard industries, based on emerging trends and strategic goals.

Note that state-plan states are also strongly encouraged to participate in the revised NEP. They may have adopted the national program or created their own program that is at least as effective as the NEP. Be aware that states may have more stringent regulations related to the focus areas in the NEP.

 

Which sectors will be targeted?

With the latest CPL 03-00-026, OSHA will select establishments with the following North American Industry Classification System (NAICS) codes for a comprehensive (wall-to-wall) safety inspection:

• NAICS 491110 — Postal Service Processing & Distribution Centers
• NAICS 492110 — Couriers and Express Delivery Services
• NAICS 492210 — Local Messengers and Local Delivery
• NAICS 493110 — General Warehousing and Storage
• NAICS 493120 — Refrigerated Warehousing and Storage
• NAICS 493130 — Farm Product Warehousing and Storage
• NAICS 493190 — Other Warehousing and Storage

Note that retail operations (in NAICS 444110, 444130, 444190, 445110, and 452311) are no longer targeted by this NEP.

OSHA and the states may pull any size establishment into these inspections, unless an establishment is otherwise exempted under the Appropriations Act. (See CPL 02-00-170, Enforcement Exemptions and Limitations under the Appropriations Act).

Also, any establishment that had a comprehensive safety inspection related to the hazards addressed by this NEP within the previous three years generally will not be subject to another inspection under the NEP itself.

What will officers look for?

Compliance officers will review OSHA 300 logs, 300A summaries, and OSHA 301 incident reports for the current and previous three calendar years to identify recorded injuries and illnesses associated with the hazards covered by this NEP. Because officers will be checking these records during the opening conference, keeping accurate records is a way to avoid a citation under 29 CFR 1904.

Officers will also be on the lookout for “common” safety and health hazards, including, but not limited to:

• Powered industrial vehicle operations,
• Material handling/storage,
• Walking-working surfaces,
• Means of egress,
• Fire protection,
• Heat, and
• Ergonomics.

Unlike the previous NEP, the directive removes the requirement for officers to perform a dedicated heat and ergonomic hazard screening.

The latest NEP explains that an inspection may be “expanded” based on fatalities/catastrophes, complaints, referrals, recorded injuries/illnesses, employee statements, or “plain view” observations. Hazards found in this way may provide a basis for expanding the inspection.

 

How might you prepare?

In addition to addressing heat and ergonomics hazards, you may wish to focus your compliance efforts on the following regulations, since they are mentioned in the NEP:

29 CFR:	Description:
1904	Recording and Reporting Occupational Injuries and Illnesses
1910 Subpart D	Walking-working surfaces
1910 Subpart E	Exit routes and emergency planning
1910 Subpart I	Personal protective equipment
1910 Subpart L	Fire protection
1910 Subpart N	Materials handling and storage

Other frequently cited standards for the covered industries are fair game for compliance officers and worth mentioning. They include 1910.94, .95, .110, .111, .119, .120, .147, .151, .212, .219, .242, .303, .305, .334, and .1200. To find the frequently cited standards for your industry NAICS code, visit www.osha.gov/ords/imis/citedstandard.html.

How might you gauge your compliance?

Because the NEP has eight areas of emphasis, they’re a good place to begin assessing your overall compliance.

1. Powered industrial trucks (PITs) (1910.178)

Two major compliance issues involving PITs are training and maintenance. Before operating a PIT, your workers must successfully complete training and be evaluated on their operating skills. OSHA also requires PITs to be examined at least daily before being placed into service. On top of daily inspections, you need to have authorized personnel perform routine checks and preventive maintenance to keep these trucks in safe operating condition.

2. Materials handling/storage (1910.176)

OSHA’s handling and storage requirements make sense for any warehouse:

• Where mechanical handling equipment is used, provide sufficient safe clearance, and mark permanent aisles;
• Stack, block, and interlock any bags, containers, bundles, and so forth that are stored in tiers;
• Limit tiered storage height so that it is stable and secure and won’t slide, fall, or collapse; and
• Do not allow storage areas to accumulate materials that create a tripping, fire, explosion, or pest-related hazard.

3. Walking-working surfaces (1910.22)

OSHA mandates that you inspect walking-working surfaces regularly. Once you determine an inspection frequency that will keep surfaces safe, stick to it. The agency also prescribes walking-working surface inspections “as necessary” when conditions warrant an additional check to ensure these surfaces are safe for workers to use. If a correction/repair cannot be made immediately, you must guard it to keep workers from using the surface. Also, think about:

• Immediately picking up debris such as packaging, banding, and broken pallets;
• Maintaining drainage systems where wet and wintery conditions exist;
• Keeping surfaces free from protruding nails, splinters, holes, or loose boards;
• Closing dock doors when not in use, to prevent falling or stepping off the dock edge;
• Not letting workers climb on or jump off docks; and
• Prohibiting workers from poking their heads outside of the dock door.

4. Exit routes (1910.37)

It’s important to know that OSHA regularly cites 1910.37 in the warehousing industry. No matter how much storage you have in your warehouse, exit routes must be free and unobstructed. Also mark your exit routes with a readily visible sign, with no other signs or distracting objects near them.

5. Fire extinguishers (1910.157)

Unless exempted, OSHA 1910.157 calls for your warehouse to mount, locate, and identify approved fire extinguishers so that they are readily accessible. Keep them fully charged and in operable condition. What’s more, ensure that workers are trained initially and annually per the standard where you either provide extinguishers for worker use or designate them to use firefighting equipment as part of an emergency action plan.

6. Injury/illness recordkeeping (29 CFR 1904)

One of the first things a compliance officer is likely to review is your safety-and-health-related records. Under Part 1904, the compliance officer may check to see that:

• The 300, 301, and 300A forms (or equivalent) are up to date for the last three years (while the NEP has a three-year look back, technically, an officer can request these records going back five years);
• The 300A form has been posted from February 1 to April 30, as required each year; and
• Your establishment has submitted its worker injury/illness data electronically and on time per 1904.41.

7. Ergonomic hazards (Occupational Safety and Health Act)

While some states may, federal OSHA does not have a standard that “requires” employers to have an ergonomics program. Yet, federal OSHA has cited employers for ergonomics hazards under Section 5(a)(1) of the Occupational Safety and Health Act. A sound framework for addressing musculoskeletal disorders may include:

• Engineering controls such as adjusting rack shelf heights or using equipment like angled shelving, turntables for pallets, or U-boat platform trucks with a spring-loaded platform;
• Administrative controls that reduce the duration, frequency, and severity of exposure;
• Training workers in lifting techniques; and
• Safe work practice controls like keeping the hands straight in line with the forearms and using boxes or totes with handholds, where suitable.

8. Heat illness (Occupational Safety and Health Act)

Some states have heat-related regulations, but federal OSHA does not. The federal agency, however, has cited warehouses under Section 5(a)(1) of the Occupational Safety and Health Act for exposing workers to excessive heat. The agency says there are several ways to materially reduce or eliminate your workers’ exposure to heat. Think about worker training in heat hazards and watch for signs and symptoms of heat illness. Also, consider:

• Cooling your work areas;
• Scheduling around the heat;
• Providing water, rest, and shade; and
• Allowing new workers to acclimatize to a hot environment.

 

Final thoughts

An OSHA inspection can be a scary prospect and knowing that your warehouse may be selected for inspection makes it more critical to prepare. It’s time to check your compliance and get your records in shape. The guidance set out above should help you get started.