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OSHA Enforces New National Emphasis Program to Address Concerns with Warehouses and Distribution Centers

Michelle Campbell | August 23, 2023

Why is OSHA concerned with Warehouses and Distribution Center Operations?

The warehousing and distribution centers industries are growing rapidly, with employment increasing from 668,900 workers in 2011 to 1,713,900 in 2021. Within these same industries, there have been high rates of illness and injury. Specifically, within the warehousing and storage industry, top illnesses and injuries in 2020 included:

  • Exposure to harmful substances or environments
  • Overexertion and bodily reaction
  • Falls, trips, and slips
  • Struck-by/Contact with object or equipment
  • Violence and other injuries by persons or animals

What changes are coming to these centers?

As of July 13, 2023, the Occupational Safety and Health Administration (OSHA) implemented a National Emphasis Program (NEP) with a focus on Warehousing and Distribution Center operations. The NEP will establish guidelines for facilities inspections to further understand the predominant workplace hazards and to increase employer and employee awareness in this rapidly growing industry. As this program is implemented, an increase in OSHA inspections of Warehouses and Distribution Centers can be expected.

Key hazards of focus for OSHA include:

  • Powered industrial vehicles operations
  • Material handling/storage
  • Walking-working surfaces
  • Means of egress
  • Fire protection
  • Hearing conservation and occupational noise exposure

Heat illness and ergonomic hazards are prevalent for many Warehouse and Distribution Center workers and will also be assessed during each inspection under the new NEP.

Inspections will predominantly be scheduled ahead of time, based on the North American Industry Classification System (NAICS) classification of a facility. Your OSHA Area Office (AO) will include your company in a “cycle,” or a subset of establishments from their Master List of facilities and will inspect the companies within the cycle in a random order. Each cycle must be performed in their specific order, but the companies within the cycle can be inspected in any order. For example, if your facility is in Cycle 2, you can always expect to be inspected after Cycle 1, but you will be unsure who within your cycle will be inspected before you. As a result, you should always be prepared for an OSHA inspection, as it is difficult to plan ahead. OSHA can also perform unprogrammed inspections as a result of fatalities, catastrophes, complaints, or referrals, as per standard OSHA regulations.

What should employers do?

The new NEP for this industry is expected to be the initial step in OSHA’s long-term strategy to develop proper regulation and instruction on the management of hazards and protection of worker health and safety at these critical facilities. As the OSHA regulations for warehouses and distribution centers continue to evolve over the next few years, it can become difficult to stay in compliance. Employers should begin to conduct hazard analyses of their facilities to identify high hazard tasks. It is recommended that a compliance audit and program review be developed to address potential regulatory compliance gaps.

TRC Can Help

TRC can help you navigate the current regulations and understand what the proposed changes could mean to your business operations. Our experienced team can also guide you to the best solutions to take your safety culture beyond basic compliance. TRC’s experienced safety professionals and industrial hygienists support OSHA audit preparation and all other health and safety compliance needs. We provides on-site audits which may include a thorough site visit, observing worker activities, conducting employee interviews and records review. We also offer remote and hybrid audits utilizing mobile applications and audit links.


Top Illnesses and Industries

Michelle Campbell

Michelle Campbell is TRC’s National Service Leader for Industrial Hygiene located in Irvine, California. She has over 19 years of experience in environment, health and safety consulting with a focus on industrial hygiene program design. Ms. Campbell’s experience includes, hazardous and regulated materials assessments; development, implementation, and management of health and safety programs; health and safety training; health and safety auditing for regulatory compliance; occupational exposure assessments; exposure banding; and hazardous waste storage and management audits. As National Servicer Leader, she is responsible for program and technical development, strategic growth and overall performance of the Industrial Hygiene Assessment and Controls Services team. Michelle can be reached at

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