Health & Safety Insights

OSHA NEP Cracks Down on Warehouse Safety: How Will Your Facility Stack Up?

Tricia Hodkiewicz, Editor - EHS

Date: 1/24/2024

Four industries now face greater odds of an OSHA visit! That’s because the agency launched an inspection program nationwide that targets the following sectors through July 2026, unless extended:

  • Warehousing and distribution operations,
  • Mail processing and distribution centers,
  • Parcel delivery and courier services, and
  • Certain high-risk retail operations.

OSHA explains that federal data show injury and illness rates for these industries are higher than in private industry overall and, in some cases, more than twice 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.



The new National Emphasis Program (NEP) on Warehousing and Distribution Center Operations (CPL 03-00-026) is one of only 13 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, too, must participate in the 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 CPL 03-00-026, OSHA has two inspection tracks:

  • The first track has comprehensive (wall-to-wall) safety inspections for warehousing and distribution operations (North American Industry Classification System (NAICS) codes 493110, 493120, 493130, and 493190); mail processing and distribution centers (NAICS 491110); and parcel delivery and courier services (NAICS 492110 and 492210).
  • The second track has inspections of just the loading and storage areas of high-risk retail operations (NAICS 444110, 444130, 444190, 445110, and 452311). OSHA selects retailers based on their days-away, restricted, or transferred (DART) rates. Compliance officers may expand the scope of these partial inspections where evidence shows that violative conditions may be found elsewhere.

OSHA and the states may pull any size establishment into these inspections.


What will officers look for?

No matter the inspection track, compliance officers will be on the lookout for “common” safety hazards, including:

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

However, where an officer comes across one of the following hazards, the scope of the inspection must be expanded, and a health inspection is opened:

  • Heat, or
  • Ergonomics.


How might you prepare?

In addition to 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:


1904.7, .29, .32, 39, .40, and .41

Recording and Reporting Occupational Injuries and Illnesses

1910.22, .23, .25, .26, .28, .29, and .30

Walking-working surfaces (WWSs)

1910.37, .38, and.39

Exit routes and emergency planning

1910.132, .133, .134, .135, .136, .138, and .140

Personal protective equipment


Portable fire extinguishers

1910.176, .178, .179, and .184

Materials handling/storage, powered industrial trucks, cranes, and slings

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.


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 PITs 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 WWSs regularly. Once you determine an inspection frequency that will keep surfaces safe, stick to it. The agency also calls for WWS 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 head 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 per the standard where you 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 may want to see is your safety-and-health-related records. That means keeping accurate records is another way to avoid an OSHA citation. 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 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 “require” employers to have an ergonomics program, but 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 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. However, federal OSHA points to its Heat Illness Prevention Campaign materials as a “blueprint” for reducing the risk of heat illness. Think about worker training in heat hazards and watch for signs and symptoms of heat illness. 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.

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