The ongoing OSHA workplace safety program and you

February 28, 2025|Compliance, Distribution Centers/Warehouse, Material Handling, News & Headlines, Safety

By Stephanie Phillips, Industry Strategy and Solutions Manager, Hyster

It’s been nearly a year and a half since the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) launched a three-year national emphasis program (NEP) to reduce and prevent workplace hazards in warehouses and distribution centers. Safety inspections, which began in October 2023, may be triggered by an infraction, targeted at establishments with high injury and illness rates or randomly assigned, depending on the protocol for your state. If you’re operating in an intense industry like manufacturing, paper and packaging, or agriculture, the main questions on your mind are likely: does this program apply to me and if so, what does that mean?

Does the program apply to you?

Because the NEP appears to focus on warehouses, distribution centers, mail and parcel processing facilities, local delivery and high-risk retail workplaces, it might seem that storage and distribution facilities run by manufacturers or other heavy-duty industries might be excluded. However, that’s not necessarily the case.

The NEP covers the following North American Industry Classification System (NAICS) codes for warehousing and distribution center operations, and mail, parcel and delivery services.

NAICS CODE	INDUSTRY	DESCRIPTION
491110	Postal service (Processing & distribution centers only)	Establishments that provide mail, parcel and express delivery services under a universal service obligation and are primarily engaged in performing one or more parts of the basic mail service, such as sorting, routing and/or delivery (except bulk transportation of mail).
492110	Couriers and express delivery services	Establishments that primarily provide air, surface, or combined mode courier and express delivery services of parcels, but do not operate under a universal service obligation. These services are generally international or between metropolitan areas.
492210	Local messengers and local delivery	Establishments providing local messenger and delivery services of small items like documents, groceries, alcoholic beverages and restaurant meal orders within a single metropolitan area. They generally provide point-to-point pick-up and delivery and do not operate as part of an intercity courier network.
493110	General warehousing and storage	Establishments that primarily operate merchandise warehousing and storage facilities, handling goods in boxes, barrels or drums and using equipment such as forklifts, pallets and racks. They are not specialized in handling bulk products of any particular type, size or quantity.
493120	Refrigerated warehousing and storage	Establishments that primarily operate refrigerated warehousing and storage facilities. Services might include blast freezing, tempering and modified atmosphere storage services.
493130	Farm product warehousing and storage	Establishments primarily engaged in operating bulk farm product warehousing and storage facilities (except refrigerated), including grain elevator storage providers.
493190	Other warehousing and storage	Establishments operating warehousing and storage facilities (except those noted above). Examples include bulk petroleum storage, lumber storage terminals, document storage and warehousing or whiskey warehousing.

Industry descriptions are abbreviated summaries, for full details visit www.census.gov/naics.

It also covers these NAICS codes for retail establishments with the highest rates of injuries and illnesses.

NAICS CODE	INDUSTRY	DESCRIPTION
444110	Home centers	Establishments that primarily sell home repair and improvement materials and supplies without a predominate merchandise line. Items include lumber, plumbing goods, electrical goods, tools, lawn and garden supplies, housewares and hardware.
444130	Hardware stores	Establishments primarily engaged in retailing a general line of new hardware items, such as tools and builders’ hardware.
444190	Other building material dealers	Establishments (except home centers, hardware stores, and paint and wallpaper stores) primarily engaged in retailing specialized lines of new building materials such as lumber, fencing, glass, doors, plumbing fixtures and supplies, electrical supplies, prefabricated buildings and kits, and kitchen and bath cabinets and countertops.
445110	Supermarkets and other grocery stores	Establishments that primarily sell a general line of food, such as canned and frozen foods; fresh fruits and vegetables; and fresh and prepared meats, fish, and poultry. Delicatessens are included, but convenience retailers are not.
452311	Warehouse clubs and supercenters	Establishments that primarily sell a general line of groceries in combination with a general line of new merchandise, such as apparel, furniture, and appliances.

Although the federal NEP applies nationwide, states have the option to adopt or adapt a state emphasis plan (SEP) that is identical to or at least as effective as the NEP in protecting workers and preventing work-related injuries, illnesses and deaths. Visit the OSHA website for details on the program for your location.

What are inspectors looking for?

The program requires safety officers to review injury and illness records (forms 300, 300A, and 301) and their reporting status, and to complete an evaluation of potential hazards throughout the facility. Inspections focus on a variety of health and safety hazards common to warehousing, including:

Powered industrial truck (PIT) operations
Material handling and storage
Walking-working surfaces
Means of egress
Fire protection

Inspections of retail operations focus primarily on storage and loading areas, but inspections can be expanded in scope if there is evidence of violations in other areas of the establishment. Additionally, if safety officers encounter heat or ergonomic hazards in any operation, they have the option to call in a health inspection officer for further investigation.

How can you prepare your operation for inspection?

Whether your operation falls under the federal OSHA plan or an OSHA-approved state plan, on-site consultations are available at no cost to help you identify areas of weakness and provide suggestions to improve health and safety. Records from the consultation are not shared with the inspection department, and no citations are issued for would-be violations if you agree to correct the problem.

Forklift safety warrants particular attention as you prepare for inspection. In many of the industries covered by the NEP, improper PIT operation is one of the primary sources of OSHA citations. Published OSHA estimates indicate that 35,000 serious injuries involving forklifts occur annually. Examples include:

Forklift tip-overs
Accidents involving pedestrians
Falling loads
Impacts with other equipment and objects

Comprehensive OSHA-compliant forklift operator training is the essential foundation for safe operation. A properly administered lift truck and pedestrian training program is the single most effective means of reducing PIT-related accidents. Operator assist technologies are also available to provide data on problem areas and operating practices that need attention, help enhance situational awareness and even automatically reinforce operator best practices.

What’s your next step?

Because the OSHA NEP isn’t set to conclude until 2026, there’s a possibility that your facility might still be selected for inspection. Be proactive. Consult the OSHA resource for our state and take advantage of the free consultation program to schedule an evaluation. Even if the NEP passes you by, it’s never a bad idea to solidify a foundation of safety for your organization.