Warehousing and distribution centers continue to be a major focus for Occupational Safety and Health Administration (OSHA). Employment in the warehousing and storage industry more than doubled between December 2015 and December 2025, while injury and illness rates in warehousing, distribution, courier, and related industries remained above the national average.
From 2020 through 2024, Bureau of Labor Statistics (BLS) data show that general warehousing and storage operations had an average recordable injury and illness rate of 5.2 cases per 100 full-time workers and a Days Away, Restricted, or Transferred (DART) rate of 4.4. In comparison, the national averages for all private industries were 2.6 and 1.6, respectively.
OSHA first established its National Emphasis Program (NEP) on Warehousing and Distribution Center Operations in July 2023. Based on continued elevated injury and illness rates, OSHA updated the program through Directive CPL-03-00-026, effective July 31, 2026. The updated NEP will remain in effect for five years.
What is the Updated NEP?
The NEP directs OSHA enforcement resources toward warehousing and distribution centers, postal processing and distribution centers, courier services, local delivery operations, and certain other warehousing industries.
The updated NEP does not create new regulatory requirements. Instead, it provides OSHA with procedures for conducting inspections and enforcing existing OSHA standards at facilities within the covered industries.
Covered facilities generally include establishments under NAICS Codes 491110, 492110, 492210, 493110, 493120, 493130, and 493190.
OSHA will use neutral and objective criteria to develop inspection lists. As a result, a facility does not need to have a recent complaint, significant injury, or elevated injury rate to be selected for a programmed inspection.
What Will OSHA Look for?
Inspections conducted under the NEP are comprehensive. OSHA identified several common hazards that may receive particular attention, including:
- Powered industrial vehicles and forklift operations;
- Material handling and storage;
- Walking-working surfaces;
- Means of egress;
- Heat-related hazards;
- Ergonomic hazards; and
- Fire protection.
OSHA Compliance Safety and Health Officers (CSHOs) will also review the facility’s OSHA 300 Logs, 300A Summaries, and 301 Incident Reports for the current year and previous three calendar years.
Employers should also verify that required electronic injury and illness records have been submitted through OSHA’s Injury Tracking Application (ITA), as failure to submit required records may result in a citation.
What Changed?
The 2026 directive replaces OSHA’s original 2023 NEP and makes several notable changes. OSHA removed high-injury-rate retail establishments from the program, eliminated mandatory screening requirements for heat and ergonomic hazards, extended the program from three years to five years, and clarified when inspections involving complaints, referrals, fatalities, or catastrophes may be expanded.
Although mandatory screening for heat and ergonomic hazards was removed, both remain areas OSHA may evaluate during an inspection.
What Should Employers Do Next?
Facilities within the covered industries should consider conducting an OSHA inspection readiness or health and safety gap assessment before an inspection occurs.
The assessment should focus on the areas identified in the NEP, including forklift operations, pedestrian and vehicle interaction, material storage, walking-working surfaces, emergency exits, housekeeping, fire protection, heat exposure, and ergonomic hazards.
Employers should also compare their written programs and training records against actual workplace practices. A program may appear to be compliant on paper while unsafe conditions or practices are still present in the facility.
Finally, employers should review their OSHA injury and illness records for completeness, accuracy, and trends that may indicate unresolved workplace hazards.
Employers in OSHA State Plan states should also monitor state-specific implementation because inspection procedures may differ from the federal program.
ALL4 will continue to monitor OSHA’s implementation of the Warehousing and Distribution Center NEP and other occupational health and safety developments. ALL4 can assist facilities with OSHA compliance evaluations, health and safety gap assessments, recordkeeping reviews, and corrective action planning.
If you have questions regarding OSHA’s updated Warehousing and Distribution Center National Emphasis Program or would like assistance preparing for a potential OSHA inspection, please contact Ayoon Ahmad at aahmad@all4inc.com or John Kelleher at jkelleher@all4inc.com.
