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Do you have a warehouse? If your company has a forklift or other powered industrial truck, chances are it also has a warehouse. However, having a warehouse onsite may increase your odds of an inspection from OSHA. That’s because the agency has several inspection programs that take aim at warehouses. What’s more, OSHA budgeted its enforcement section to put more emphasis on the employee hazards in warehouses nationwide.

OSHA budget takes aim

OSHA’s Fiscal Year 2023 budget justification calls out warehouse enforcement specifically. While previous justifications mentioned warehouses for compliance assistance, training, or statistics efforts, the latest one puts warehousing (and courier) industries squarely in the enforcement bull’s eye. OSHA explains that the agency will increase safety and health inspections, and some of these “will consist of those addressing hazards [that] essential and vulnerable workers are exposed to in … warehousing or courier industries.”

Three OSHA Regions have emphasis programs

It’s also important to note that three OSHA Regions have inspection programs, called “Regional Emphasis Programs” or REPs, that target warehouses! These include:

  • Region 2 — The REP (2019-05) covers 40 sectors in the warehousing, wholesale distribution, and refuse handling industries in New Jersey, New York, Puerto Rico, and the Virgin Islands. These inspections are wall-to-wall, but the focus is on struck-by, caught-in, caught-between, and falling-off hazards associated with vehicles and equipment, including powered industrial trucks, motor vehicles, and conveyors.
  • Region 3 — The REP (CPL 2022-01) covers nine sectors in warehousing, retail, manufacturing, and wholesale trade industries in Delaware, Maryland, Pennsylvania, Virginia, West Virginia, and the District of Columbia. These inspections are also wall-to-wall, and federal OSHA officers are focused on a variety of hazards — powered industrial trucks; storage racks; means of egress; fire suppression; lockout/tagout; ergonomics; slips, trips, and falls; chemicals; heat; and injury and illness records.
  • Region 9 — The REP (CPL 04-00-03) covers 10 sectors in the warehousing, wholesale trade, retail trade, and manufacturing industries in Arizona, California, Hawaii, Nevada, as well as American Samoa, Guam, and the Northern Mariana Islands. The inspections are wall-to-wall, and inspectors are looking at powered industrial trucks, means of egress, fire suppression, and injury and illness records.

Department of Labor investigates

Even the Department of Labor (DOL) Office of Inspector General (OIG) with oversight over OSHA is examining an uptick in severe injuries at online retailers’ warehouse facilities. The latest DOL OIG Audit Workplan posted last month explains that this audit will review what, if any, actions OSHA has taken to address the rising injury rates and severity of injuries at these warehouse facilities.

Is there a National Emphasis Program in the works?

It’s worth noting that in December of last year, the DOL OIG sent a memo to OSHA requesting the agency to send OIG a copy of “the Draft Warehouse NEP that is currently in development” and “data that prompted OSHA to draft a Warehouse NEP.” An NEP is a national emphasis program that targets hazards or industries for OSHA inspection.

However, a spokesperson for OSHA said last month, “OSHA has not begun development on an NEP for warehouses.” When pressed whether the agency has plans to develop an NEP, the agency spokesperson would not confirm or deny that OSHA has such plans. Instead, the spokesperson explained that the only thing that can be confirmed is that NEP development has not begun.

A spokesperson for DOL OIG was unable to provide comment on the 2021 request for “the Draft Warehouse NEP.”

Key to remember

Having a warehouse onsite may increase your odds of an inspection from OSHA. In addition, the DOL OIG is investigating an uptick in severe injuries at online retailers’ warehouse facilities.