OSHA Brings Comprehensive Safety Inspections to Warehouses Nationwide

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) launched a Nationwide Emphasis Program (NEP) bringing comprehensive safety inspections to warehouses and distribution centers nationwide to identify violations related to specific targeted hazards. This is a three-year emphasis program that went into effect on July 13, 2023. OSHA area offices will be given master lists of all facilities in their geographical area with a North American Industry Classification System (NAICS) code for Warehousing and Distribution Center Operations, Mail/Postal Processing and Distribution Centers, and Parcel Delivery/Courier Services. OSHA area offices will work their way through the lists conducting comprehensive safety inspections focused on hazards related to powered industrial trucks, material handling and storage, walking and working surfaces, means of egress, and fire protection. Heat and ergonomic hazards will be noted during all inspections and an additional health inspection will be performed if those hazards are present. The following table shows NAICS codes that will be covered under this NEP.

Why warehouses, why now?

The warehousing and distribution center workforce is experiencing tremendous growth, with close to 2 million people employed in the industry nationwide. The Bureau of Labor Statistics data shows injury and illness rates for these establishments to be well above the rate of private industry. OSHA stated that warehousing and distribution center operations pose a variety of serious safety and health hazards including, but are not limited to:

• Struck-by.
• Elevated work.
• Caught-in-between.
• Confined Spaces.
• Lockout/Tag out.
• Blocked aisles.
• Heat Illness.
• Electrical hazards.
• Slips, trips, and fall hazards.
• Powered Industrial Truck operations.

Incidents resulting from the above-mentioned hazards have resulted in death or serious physical harm in growing rates over the last decade. The need for this NEP is displayed in a recent warehouse fatality investigation done by OSHA involving  a preventive powered industrial truck accident taking the life of warehouse laborer with more than four years on the job.

What is the Scope?

This NEP covers both programmed and unprogrammed safety inspections, emphasizing that it is a matter of when, not if, OSHA will inspect a facility. Unprogrammed Inspections are based upon fatalities, complaints, or referrals related to establishments in the specified NAICS codes. Along with those NAICS code, high injury rate Retail Establishments will also be covered under this NEP. Programmed safety inspections will come from the master list given to each OSHA area office, individual area offices can choose to randomize the list or work their way down in order. Per “National Emphasis Program on Amputations in Manufacturing Industries” workplace hazards targeted by this NEP will be:

• Powered Industrial Truck operations.
• Material handling/storage.
• Walking-working surfaces.
• Means of egress.
• Fire protection.
• Heat and ergonomic hazards must be considered and documented during each inspection under this NEP.

If your facility currently follows your State Plan for any of the above hazards, it is important to note that due to the seriousness and prevalence of these hazards nationwide, State Plans are required to participate in this new NEP. State Plans have the option of adopting an identical or different emphasis program, but the program must be at least as effective as this directive.

Next Steps

Facilities with any of these potential hazards need to be able to fully understand the depth of their responsibilities according to OSHA. This includes, but is not limited to, the trainings and refreshers they are providing employees, having up to date policies and plans, proper designations on powered industrial trucks and battery maintenance/storage, thorough audit documentation, complete OSHA injury and illness logs, and up to code facilities- free from hazardous conditions. This NEP was created to identify and reduce or eliminate hazards during warehousing and distribution center operations and OSHA will be conducting comprehensive inspections which they define as “a substantially complete and thorough inspection of all potentially hazardous areas of the establishment.”

If you have questions regarding compliance with OSHA regulations or would like to discuss gap assessments and compliance strategies before your inspection, please contact your ALL4 Project Manager or Cindy Castillo at ccastillo@all4inc.com. We would be happy to assist you in preparing for these inspections in any way we can.