Under the Biden administration, the Occupational Safety and Health Administration (OSHA) has issued five National Emphasis Programs (NEPs) since 2021. Because OSHA doesn’t have the personnel to inspect every workplace in America, NEPs, along with Local and Regional Emphasis Programs (LEPs, REPs), enable the agency to focus its enforcement resources.
Starting in July 2021, the agency unveiled a program of outreach and enforcement to address workplace COVID-19 exposures followed by an NEP for indoor and outdoor heat exposures in April 2022.
Earlier this year, OSHA issued a revised NEP for combustible dust and a new fall protection NEP.
This month, OSHA launched an NEP focused on distribution centers and warehouses, high-risk retail establishments, and postal processing facilities.
Is your industry targeted by the new NEP? If so, will you be ready when an OSHA inspector shows up?
Workplaces targeted under the NEP include:
- Postal service processing and distribution centers;
- Local delivery and messengers, couriers, and express delivery services;
- General warehousing and storage;
- Refrigerated, farm product, and other warehousing and storage;
- Hardware stores, home centers, and building material dealers;
- Supermarkets and grocery stores; and
- Warehouse clubs and supercenters.
OSHA cited Bureau of Labor Statistics (BLS) data showing injury and illness rates at these workplaces are significantly higher than in other industries.
Enforcement begins following a 90-day outreach effort, which includes letters and news releases to trade magazines about the NEP, as well as education, meetings, speeches, and training involving employers, labor unions, and professional associations.
Enforcement under the new NEP supersedes similar local and regional warehousing emphasis programs. For example, OSHA’s Region 3 office last year launched an REP for warehouse operations in Delaware, the District of Columbia, Pennsylvania, and West Virginia that included a focus on ergonomic and heat hazards.
The new NEP will include comprehensive safety inspections focused on hazards related to powered industrial vehicle operations, material handling and storage, walking and working surfaces, means of egress, and fire protection. Agency inspectors will also conduct health inspections if ergonomic or heat hazards are present in a facility.
Hazards in warehouses and distribution centers include struck-by hazards; caught-in and caught-between hazards; slip, trip, and fall hazards; blocked aisles; means of egress; powered industrial trucks and other material-handling equipment; heat hazards; and ergonomic hazards.
Agency compliance safety and health officers (CSHOs) will also inspect the storage and loading areas of retail establishments with high injury rates.
OSHA area offices will select establishments for inspection from two lists: establishments with industry codes covered under the emphasis program and a limited number of retail establishments with the highest rates of injuries and illnesses resulting in days away, restricted duty, or job transfer.
Powered industrial trucks
OSHA’s powered industrial truck standard is the agency’s most frequently cited standard in the warehousing and storage industry.
If you use forklifts or other powered industrial vehicles in your facility, you need a full compliance program. Your compliance program must address operator training and certification, as well as operation and maintenance, including battery changing or charging and fueling of forklifts and other powered industrial trucks.
During an inspection, an agency CSHO may look at compliance issues such as whether industrial trucks meet industry design standards; supervisors’ awareness of equipment designations; operators’ knowledge of proper powered industrial truck use; fuel handling and storage; changing and charging batteries; proper bridge plates and dock boards; operator training; proper traveling, loading, and operation; and maintenance. They will also look at your OSHA 300 logs and OSHA 300A summaries for workplace injuries involving forklifts.
In addition to the warehouse NEP, there also are powered industrial truck emphasis programs in Region 1, Region 4, Region 5, Region 7, and Region 10.
Material handling and storage
Did you know material handling 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 all industries.
OSHA’s material-handling standard includes requirements for 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.
Bags, bundles, and containers in a warehouse 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 material-handling equipment is used, safe clearances must be maintained for aisles, at loading docks, through doorways, and wherever making passage or turns. Equipment must be kept in good repair and aisles and passageways kept clear, with no obstructions across or in aisles.
Walking and working surfaces
Under OSHA’s walking-working surfaces regulations, all passageways and surfaces must be kept in “a clean, orderly, and sanitary condition.” The regulations guard against hazards like clutter, obstructions, or wet conditions that might lead to slip, trip, and fall injuries.
Spills should be cleaned up and reported immediately, and grease shouldn’t be allowed to accumulate. Materials and supplies should be stored appropriately to maintain clear walking paths.
During a facility walkaround, OSHA inspectors will look for clutter and merchandise, materials, or supplies that might obstruct a corridor, path, or passageway.
Means of egress
Emergency exit routes, or “means of egress,” are a foundational worker safety protection. OSHA regularly cites employers for blocked exit routes.
Most workplaces must have at least two designated exit routes, but you may need additional routes for a larger building or workforce or a space configuration that would impede the safe exit of all employees, customers, and visitors during an emergency.
Exit access must be at least 28 inches wide, and ceilings of exit routes must be at least 7 feet, 6 inches high. Exit doors must be unlocked from the inside. Exit routes must remain free of explosive or highly flammable furnishings or decorations.
If the direction of an exit route isn’t immediately apparent, you must post signs indicating the correct direction of travel. Any doors that could be mistaken for an exit door must be marked “Not an Exit” or with a sign identifying its use, such as “Closet.”
Exit routes must be maintained during any building alteration or renovation, construction, or repairs. The exit path must have adequate lighting for employees with normal vision.
Exit routes should never be designed in a way that employees would have to travel toward a high-hazard area unless the path of travel is effectively shielded from the high-hazard area.
Heat and ergonomics
An inspector will assess ergonomic and heat hazards during a review of injury and illness records, worker interviews, and a facility walkthrough. If an inspector observes any ergonomic or heat hazards, a health inspection will be opened.
An inspection for heat hazards will follow the agency’s procedures in the indoor and outdoor heat hazards NEP.
Musculoskeletal disorders (MSDs), sometimes called “ergonomic injuries,” include back strains and sprains, carpal tunnel syndrome, rotator cuff tears, and tendonitis, usually resulting from awkward or static postures, forceful exertions, or repetitive movements.
MSD risks are well known in distribution and warehousing—manual material handling presents a risk for worker MSDs.
The National Safety Council (NSC) has called MSDs the most common workplace injury across all industries and characterizes MSDs as a significant challenge for employers, stating that 30 percent of unwanted days away from work are due to MSDs.
Some ergonomic interventions rely on recommended motions or postures, while others involve engineering controls like assistive equipment or tools.
If your facility isn’t air-conditioned, an OSHA inspector will look for elements of a heat illness prevention program.
Elements of a program for indoor heat hazards might include:
- Developing a formal heat illness prevention program and collecting temperature and heat index measurements inside your facility to assess your prevention program control measures.
- Developing emergency response procedures for signs and symptoms of heat illness and providing employees and supervisors with training.
- Providing fresh, cool drinking water free of charge.
- Maintaining cooldown areas within your facility.
- If your heat illness prevention program includes employee heat acclimatization, ensure supervisors closely observe employees during heat acclimatization periods.
Keep in mind that even if your facility isn’t selected for inspection under the warehousing and distribution center NEP, you could be targeted by the agency’s outdoor and indoor heat-related hazards NEP. OSHA stated in its warehouse and distribution center NEP that many industries are targeted by both programs. The heat-hazard NEP targets 70 high-risk industries in indoor and outdoor work settings.
Fire protection
You need to train your employees on fire hazards in your facility and your facility’s evacuation procedures.
Employees expected to fight workplace fires need access to appropriate firefighting equipment and training on how to use it. If you have portable fire extinguishers in your facility, employees need hands-on training on how to use them.
Fixed extinguishing systems can detect a fire, sound an alarm, and supply water or another fire-suppression agent to extinguish a fire. If you have a system that uses gaseous agents, you must post signs for fire-suppression agents that pose a serious health hazard.
If you have a fixed extinguishing system, then you must have a fire watch of trained employees who can respond to a fire emergency when your fire-suppression system is out of service.
Prepare now
The warehouse and distribution NEP was issued in June and became effective July 13. The program terminates 3 years after its effective date.
Like all emphasis programs, it kicks off with a 90-day outreach effort. You may want to avail yourself of OSHA’s compliance assistance during the outreach period.
When the agency unveiled its NEP, Doug Parker, assistant secretary of labor for occupational safety and health, released a statement saying, “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.”
He added, “Our enforcement efforts are designed to do one thing: lead to permanent change in workplace safety.”