OSHA NEP – Warehousing & Distribution

Property & Casualty, Risk

Beginning July 13th 2023, OSHA has implemented a National Emphasis Program targeting warehousing a distribution centers, mail/postal processing and distribution centers, parcel delivery/courier services, and certain high injury rate retail establishments. The decision comes as injury rates for affected operations have seen a sharp increase in recent years. OSHA will treat inspections that fall under this program as partial inspections, citing the ability to expand an investigation when there is evidence of additional violations uncovered during the inspection. The program will extend until July 13th 2026.

Why has OSHA made this decision?

Within the last ten years (2011-2021), the warehousing and distribution industry has seen a large employment boost. Much of this growth is due to shifts in consumer behavior, particularly the increase in e-commerce and demand for faster delivery times. Within this time frame, the industry employed 1,045,000 new employees since 2011. In turn, employee injuries have been on the rise when compared to all private industry.

Additional Considerations

Within the Full Directive, OSHA states they will prepare a list of high injury rate retail establishments in the NAICS codes they have identified. They will then identify specific establishments subject to inspection based on DART rate information submitted into the Injury Tracking Application. Meaning those with a DART rate higher than industry average are more likely to receive an inspection.

Understanding Your Company’s Process for Handling an OSHA Inspection Is Key:

  • Familiarize yourself with your company’s established protocols for managing OSHA inspections.
  • Identify key points of contact, including the designated OSHA coordinator, safety manager, and relevant department heads.
  • Ensure all employees know their roles and responsibilities during an inspection.

Key Takeaways:

  • OSHA’s National Empasis Program on Warehousing and Distribution Centers will be in effect from July 13th 2023 – July 13th 2026
  • Under the program, key areas of focus are:
    • Powered Industrial Vehicle Operations
    • Material Handling/Storage
    • Walking-Working Surfaces
    • Means of Egress
    • Fire Protection
    • Heat & Ergonomic Hazards
  • Familiarizing yourself with the OSHA inspection process is imperative to put your best foot forward. To learn more about what to expect before, during, and after an OSHA inspection feel free to watch M3’s recorded webinar detailing the process further.


Reach out to your M3 team with any questions you may have about OSHA.

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