Enforcement and Inspection

Is Your Warehouse Ready for an OSHA Inspection?

Is your warehouse prepared for the arrival of an Occupational Safety and Health Administration (OSHA) inspector? Warehouses and storage are on the agency’s primary industry target list under its National Emphasis Program (NEP) for COVID-19.

In fact, OSHA already has cited and fined a Naperville, Illinois, logistics center following an outbreak of COVID-19 in which one worker died. The agency proposed a $12,288 penalty for a serious violation of the Occupational Safety and Health (OSH) Act’s General Duty Clause.

OSHA considers warehouses and storage a high-risk industry and targets the industry in its NEP for COVID-19 safeguards, along with ambulance and home healthcare services; correctional facilities; department stores, groceries, supermarkets, and restaurants; healthcare and long-term care facilities; and meatpacking and poultry processing facilities. Under the NEP, OSHA area offices may include warehouses and healthcare and meatpacking facilities on a list for priority inspections.

During an inspection under the COVID-19 NEP, agency personnel will begin by examining the workplace injury and illness log (OSHA Form 300), looking for cases, hospitalizations, lost time, and fatalities. OSHA inspectors then will check for adherence to the agency’s Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. They will check for multiple layers of controls such as mask wearing, distancing, and increased ventilation. In areas with high levels of SARS-CoV-2 transmission, the agency will look for infection controls even if most of the workforce is fully vaccinated. In non-healthcare workplaces like warehouses, OSHA will cite any lapses in COVID-19 protections using its authority under the OSH Act’s General Duty Clause. However, agency personnel also will check for compliance with other standards like sanitation, signs and tags, and respiratory protection.

If you provide workers with respirators like N95 masks, OSHA will look for a fully compliant respiratory protection program complete with medical evaluations, initial and annual fit testing, and training. Workers provided with respirators need to understand how to perform a user seal test.

Obvious hazards, frequently cited standards

The OSHA standards most frequently cited in warehouses involve some of the more obvious warehouse safety hazards like forklifts, hazard communication (HazCom), obstructed exit routes, and material handling. Did you know material handling also is responsible for many warehouse injuries and is a major contributor to workers’ compensation costs? One workers’ compensation insurer found that material-handling incidents accounted for 32 percent of all its workers’ compensation claims across industries.

Some of the agency’s most frequently cited standards in warehouse inspections include:

  • Powered industrial trucks (29 CFR §1910.178);
  • HazCom (§1910.1200);
  • Maintenance, safeguards, and operational features for exit routes (§1910.37); and
  • Handling materials (§1910.176).

Forklifts

Powered industrial trucks, commonly referred to as forklifts or lift trucks, are common in many industries, but OSHA’s powered industrial trucks standard is the most frequently cited one in warehouse and storage. The standard includes provisions covering operator training and certification and safe forklift operation, as well as battery changing and charging, the control of noxious fumes or gases, forklift maintenance, fuel handling and storage, lighting for forklift operational areas, and safety guards.

Operators should wear a safety belt or restraint if the forklift is equipped with one and should never exceed the forklift’s rated load and never lift or lower loads while traveling. They must be aware of other vehicles, watch for workers on foot, and use horns at cross aisles and in areas with obstructed views. They need to have clear visibility of the work area and ensure they have enough clearance when raising, loading, and operating the forklift.

Forklifts can pose an injury hazard to both operators and other workers in a warehouse, even a fatal hazard. Fatal incidents involving forklifts have included forklift overturns, workers struck by a forklift, workers crushed by a forklift, and falls from a forklift, according to the National Institute for Occupational Safety and Health (NIOSH).

The institute recommends making every effort to alert workers when a forklift is nearby, using horns, audible backup alarms, and flashing lights to warn workers and other forklift operators in the area. In areas where the ambient noise level is high, flashing lights may be the best way to alert others to a forklift’s presence.

Forklift operators must be trained and licensed, and NIOSH recommends developing a training program with a timetable for refresher training, as well as regular reevaluation of the program itself.

Operators of sit-down-type forklifts should use provided operator restraints and be informed that they can be crushed by the overhead guard or another part of the truck after jumping from an overturning forklift. They should stay with the truck if a lateral or longitudinal tipover occurs and hold on firmly and lean away from the point of impact.

As a warehouse and storage employer, you should separate forklift traffic and other workers wherever possible, limiting some aisles to forklifts only or workers on foot only. You also should restrict the use of forklifts near time clocks, break rooms, cafeterias, and main exits, particularly when the flow of workers on foot is at a peak, like at the end of a shift or during breaks. You also need to evaluate intersections and blind corners to determine whether overhead dome mirrors could improve visibility for forklift operators or workers on foot.

Chemical safety: HazCom

While forklift compliance may be a common requirement in most warehouses, some warehouses also will need a robust HazCom program to manage chemical hazards. After the powered industrial trucks standard, the HazCom standard is the most frequently cited standard in warehouses.

You should understand what an OSHA inspector will look for during an investigation. If a compliance safety and health officer (CSHO) is aware of the presence of hazardous substances, the CSHO will look for a written HazCom program covering all employees who may be exposed. At a multiemployer worksite like a warehouse staffed by employees of a logistics company, both host and contract employers are responsible for HazCom compliance, and OSHA will site both employers for violations.

The program must include information and procedures for labels and other warnings, safety data sheets (SDSs), and employee training.

A CSHO will look at how a contractor’s employees access SDSs for substances on-site and how they are informed of and trained on chemical hazards in the workplace and the necessary precautions for substances at the facility. The CSHO will interview employees, managers, and supervisors to assess all aspects of workplace HazCom compliance—labels, SDSs, information, and training. An agency inspector will check for the person or persons responsible for label and SDS compliance and training and information compliance.

One of the biggest workplace chemical safety challenges is the huge number of hazardous chemicals without any regulatory or even a peer-reviewed occupational exposure limit (OEL). While over 86,000 commercially available chemicals are included on the Toxic Substances Control Act (TSCA) Chemical Substance Inventory, only about 1,000 have a government, consensus, or peer-reviewed OEL, according to NIOSH.

In such instances, NIOSH recommends a “control banding” approach. The NIOSH Occupational Exposure Banding Process for Chemical Risk Management offers a strategy for assigning chemicals to a category or “band” to decide how to best protect workers from harmful exposures.

NIOSH’s approach involves:

  • A three-tiered system directed toward users of varying expertise. Tier 1 substances would require relatively little information or specialized training, Tier 2 substances would require either an occupational hygienist or safety managers trained in chemical risk management, and Tier 3 substances would require the kind of expert judgment that only a toxicologist or an experienced occupational hygienist would have.
  • A method for determining health impacts by considering nine separate health outcome criteria that include acute toxicity, carcinogenicity, and skin sensitization.
  • Hazard-based categories linked to ranges of exposure.
  • A process to determine exposure bands by comparing substances with chemicals with existing OELs.

Exits, material handling

We recently covered exit routes in depth, along with OSHA’s emergency action plan requirements. Maintaining exit routes has been a foundational safety precaution ever since the March 25, 1911, Triangle Shirtwaist Factory fire that led to 146 worker deaths.

Federal requirements for maintaining exit routes include:

  • Keeping exit routes free of explosive or highly flammable furnishings and other decorations and free of decorations or signs that would obscure the visibility of the doors;
  • Posting signs indicating the safe direction of travel if the direction of exit access and point of discharge are not immediately apparent;
  • Marking doors along the exit access that could be mistaken for exit doors with a “Not an Exit” sign or a sign identifying the doors’ use, such as “Closet”;
  • Protecting exit routes with fire-resistant materials and fire-retardant paints or solutions along the exit access and renewing them often enough to maintain their fire-retardant properties;
  • Maintaining exit routes during any alteration or renovation, construction, or repairs;
  • Arranging exit routes so that employees will not have to travel toward a high-hazard area, unless such a path of travel is effectively shielded from the high-hazard area;
  • Keeping exit routes unobstructed by materials, equipment, locked doors, or dead-end corridors; and
  • Having lighting along exit routes that is adequate for employees with normal vision.

The provisions of the material-handling standard include clearance signs warning employees and others of clearance limits, material covers and guarding, housekeeping, rolling railroad cars, secure storage, and the use of mechanical equipment. Materials in a warehouse must be securely stored to prevent struck-by hazards. Bags, bundles, and containers must be stored in tiers, stacked, blocked, and interlocked, and stack heights should be limited so that stacks are stable and secure against sliding or collapse.

Storage areas must be kept free from an accumulation of materials that would present hazards from explosion, fire, pests, or tripping. Permanent aisles and passageways must be appropriately marked, and any vegetation must be controlled if necessary.

If mechanical-handling equipment is used, safe clearances must be maintained for aisles, at loading docks, through doorways, and wherever turns or passage must be made. Equipment must be kept in good repair and aisles and passageways kept clear, with no obstructions across or in aisles.

Manual material handling presents a risk for worker musculoskeletal disorders (MSD). NIOSH has provided employer guidance in its Ergonomic Guidelines for Manual Material Handling. The institute offers ergonomic interventions that can lower the physical demands of manual material-handling tasks.

Given that OSHA is targeting warehouse and storage under its COVID-19 NEP, now is the time to check your compliance with the powered industrial trucks, HazCom, exit routes, and material-handling standards.