Is Your Facility OSHA Inspection Ready?


Learn more about OSHA’s new national emphasis program for warehouses and distribution centers.


Inspections for the Occupational Safety and Health Administration’s (OSHA) National Emphasis Program (NEP) on Warehousing and Distribution Center Operations began on October 13, 2023. Announced this past summer as directive number CPL 03-00-026, the goal is to reduce and eliminate hazards in warehousing and distribution centers, mail/postal processing and distribution centers and parcel delivery/courier services.

Additionally, the loading and storage areas of certain retail establishments—such as home centers, hardware stores, supermarkets, building material dealers and warehouse clubs—also have high injury rates. Therefore, they are also included in the program. OSHA national, regional and area offices, as well as state plans and onsite consultation programs, will be executing its directives.

your facility osha“Our enforcement efforts are designed to do one thing: lead to permanent change in workplace safety,” said assistant secretary of labor for Occupational Safety and Health Doug Parker. “This emphasis program allows OSHA to direct resources to establishments where evidence shows employers must be more intentional in addressing the root causes of worker injuries and align their business practices with the goal to ensure worker health and safety.”

Why OSHA Is Prioritizing Warehouse and Distribution Safety

Currently set to run for three years, the NEP specific to warehouses and distribution centers is in response to the tremendous rate of growth experienced in these industries over the past decade. Today, more than 1.9 million people work in one of the aforementioned facilities.

“At the same time, Bureau of Labor Statistics data show injury and illness rates for these establishments are higher than in private industry overall and, in some sectors, more than twice the rate of private industry,” added Doug Kalinowski, directorate of cooperative and state programs at the U.S. Department of Labor and OSHA.

The agency notes that the most common safety and health hazards in warehousing and distribution include being struck by moving vehicles or caught in between equipment; slips, trips or falls; blocked aisles; unclear exits; powered machinery; heat hazards; and improper ergonomics. Incidents associated with those dangers can result in serious injuries or fatalities.

Under the NEP, OSHA’s Compliance and Safety Health officers from its area offices will conduct comprehensive safety inspections of all facilities in their jurisdiction included in a randomly assigned list. The agency will specifically focus on hazards related to:

  • Powered industrial vehicles
  • Material handling and storage
  • Walking and working surfaces
  • Means of egress
  • Fire protection

Additionally, although OSHA does not have regulations regarding excessive heat or ergonomics, the agency advised that it will evaluate those areas in the warehousing and distribution facilities its inspectors visit. If such hazards are present, a health inspection may be opened.

MHI Solutions interviewed Kimberly Darby in the Office of Communications at the U.S. Department of Labor and OSHA for guidance on how warehouse and distribution center operators can do just that, as well as to learn more about the new program.

MHI Solutions: What can facilities do to prepare for an inspection?

Darby: Normally, OSHA conducts inspections without advance notice. The Occupational Safety and Health (OSH) Act contains a general prohibition against giving advance notice of inspections, except as authorized by the Secretary or the Secretary’s designee.

The Act regulates many conditions that are subject to speedy alteration and disguise by employers. To forestall such changes in worksite conditions, the Act prohibits unauthorized advance notice.

MHI Solutions: What does OSHA require of employers?

Darby: Under the OSH law, employers have a responsibility to provide a safe workplace. Key employer responsibilities include:

  • Provide a workplace free from serious recognized hazards and comply with standards, rules and regulations issued under the OSH Act.
  • Examine workplace conditions to make sure they conform to applicable OSHA Standards.
  • Make sure employees have and use safe tools and equipment and properly maintain this equipment.
  • Use color codes, posters, labels or signs to warn employees of potential hazards.
  • Establish or update operating procedures and communicate them so that employees follow safety and health requirements.
  • Provide safety training in a language and vocabulary workers can understand.
  • Provide medical examinations and training when required by OSHA Standards.
  • Post the OSHA poster, or the state-plan equivalent, at a prominent location within the workplace. The poster informs employees of their rights and responsibilities.

Additionally, employers with hazardous chemicals in the workplace must develop and implement a written hazard communication program and train employees on the hazards they are exposed to and proper precautions. A copy of safety data sheets must also be readily available.

Employers must report all work-related fatalities to the nearest OSHA office within eight hours, and all work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours. Call our toll-free number: 1-800-321-OSHA (6742); TTY 1-877- 889-5627. Note that employers under federal OSHA’s jurisdiction were required to begin reporting by January 1, 2015. Establishments in a state with a state-run OSHA program should contact their state plan for the implementation date.

Also, keep records of work-related injuries and illnesses. Employers with 10 or fewer employees and employers in certain low-hazard industries are exempt from this requirement. More information on employer responsibilities can be found at

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