Cracking OSHA's warehouse safety code

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September 7, 2023 - Warehouses experience a higher rate of fatal injuries compared to the national average across all industries. OSHA reports that every year, nearly 100 people are killed and 95,000 people are injured in forklift accidents alone, and that doesn't account for injuries related to other safety hazards like slips, trips, and falls, repetitive stress, or hazardous materials exposure.

From 2011 to 2021, the number of people working in warehouses and distribution centers shot up from 668,900 to a whopping 1,713,900. But here's the flip side: during that same time, this industry saw high rates of job-related injuries and illnesses.

Warehouses and distribution centers encounter significant safety challenges, including the potential hazards of falling objects, confined spaces, unexpected slips, trips, and exposure to dangerous substances. Add to those concerns narrow or jammed aisles, maneuverability difficulties, the dangers linked to handling heavy materials, workers or workspaces getting overheated, and worries about overuse injuries. These issues are far from trivial; and can lead to severe injuries, or worse.

Understanding warehousing and distribution operations:

OSHA's National Emphasis Programs (NEPs) zero in on workplace safety hazards and aims to safeguard both employees and operations while proactively tackling risks. The Warehouse Distribution Operations (WDO) NEP took effect nationally on July 13, 2023; however, understanding the nuances of this program can be difficult.

WDO objectives

This program focuses on three main objectives:

• Risk identification: The primary goal of the WDO NEP is to identify and evaluate safety hazards prevalent in the industry. This includes but is not limited to issues related to forklift operations, material handling, hazardous materials, ergonomics, and slips, trips, and falls.
• Outreach and education: The NEP recommends collaboration with employers, workers, industry associations, and safety professionals to raise awareness about potential risks and the importance of implementing safety measures. Educational outreach helps stakeholders better understand OSHA standards and the benefits of maintaining a safe work environment.
• Compliance inspections: The NEP includes targeted inspections of warehouses and distribution centers nationwide to assess their compliance with OSHA regulations. Comprehensive safety inspections are conducted to identify any violations and provide recommendations for corrective actions.

State plans

The NEP requires state plans to participate by adopting an identical program or an emphasis plan that is at least as effective as the NEP. State plans must submit a notice of intent within 60 days of the effective date (July 13) and the state plan adoption must be accomplished within six months. Summaries of the state plan responses will be posted.

Process breakdown

The OSHA instruction document, Directive Number CPL 03-00-026, outlines the strategies for site selection, inspection scheduling, inspection procedures, outreach programs, and program reviews.

• Site Selection: Two lists are provided, one for general establishments (Table 1) and another for high-injury rate retail establishments (Table 2). Establishment lists are generated in random order for those establishments in the local jurisdiction of each Area Office (AO).
• Inspection Scheduling: The AO will establish a cycle for inspections. A “cycle” (subset of establishments from the master list) allows the AO to schedule resources efficiently.
• Inspection Procedures: All inspections will be conducted according to the Field Operations Manual (FOM), Chapter 3, Inspection Procedures.
• Outreach Programs: Each Regional Office (RO) and AO will implement a 90-day outreach program, offering outreach to the industries covered in Table 1 prior undergoing the NEP-related inspections.
• Program Review: The Directorate of Enforcement Programs (DEP) will review NEP outcomes within 12 months per ADM-03-00-003. Data may include:
• number of employers covered.
• number of workers removed from hazards.
• abatement measures implemented.
• number of violations related to targeted hazards.
• any indices related to measure that may be included in the Department of Labor (DOL) Strategic Plan and/or the OSHA Agency Management Plan.

Table 1: The general NAICS codes covered under this NEP include:

Table 2: High-Injury Rate Retail Establishment NAICS codes covered under this NEP include:

Warehousing and distribution is one of the fastest-growing sectors, with some of the highest-risk environments. By identifying risks, educating employers and employees, and enforcing compliance, the NEP contributes to the reduction of workplace incidents and helps to create safer environments. (Visit OSHA warehousing.)

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