Back to Basics is an article series that highlights important, but possibly overlooked, information facilities management professionals should know.
The injury rate for workers in the warehousing and storage industry is 4.8 injuries per 100 workers, according to Bureau of Labor Statistics (BLS) data—higher than the average rate of 2.7 injuries per 100 workers for all U.S. private industry.
Safety hazards in transportation and warehousing can also be costly for employers. Insurer Liberty Mutual estimates the serious, nonfatal workplace injuries in the industry cost employers $4.81 billion in workers’ compensation claims for medical expenses and lost wages. The top causes of injuries were handling an object (“overexertion involving outside sources”), falls on the same level, awkward postures (“other exertions or bodily reactions”), and falls to a lower level.
The federal Occupational Safety and Health Administration (OSHA) has a national emphasis program (NEP) that focuses on outreach, inspection, and enforcement for warehouses and distribution centers. The agency’s Philadelphia regional office also has a regional emphasis program (REP) for warehouse operations.
When the agency launched its NEP in 2023, it acknowledged the tremendous growth in warehouses and distribution centers over the previous 10 years. The industry had grown to employ nearly 1.9 million workers. However, with that growth came injury and illness rates higher than in private industry overall, with some sectors experiencing rates more than twice that of private industry.
The NEP is focused on compliance with the agency’s standards for walking-working surfaces, exit routes, personal protective equipment (PPE), fire protection, and materials handling and storage. The Philadelphia region REP is focused on ergonomics and the prevention of musculoskeletal disorders (MSDs), as well as indoor heat-related hazards.
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; and ergonomic hazards, according to OSHA.
Workers’ exposure to ergonomic hazards is assessed during a review of employers’ injury and illness logs.
Some facilities targeted by the warehouse and distribution NEP may also be targeted under the indoor and outdoor heat-related hazards NEP. In those facilities, safety inspections under the warehouse and distribution NEP and health inspections under the heat hazards NEP may be conducted concurrently.
Workplaces targeted under the warehouse and distribution center 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.
Area offices choose sites for inspection from two lists: a list of establishments with industry codes covered by the NEP and a list of a limited number of retail establishments with the highest rates of injuries and illnesses resulting in days away, restricted duty, or job transfer (DART).
Inspection procedures under the NEP include checks of a facility’s injury and illness records, training programs, worker knowledge of how to address hazards of warehouse work, and screening for ergonomic and heat hazards.
OSHA’s Philadelphia regional office launched its own emphasis program in 2022 in response to the ongoing growth of e-commerce. The program focuses on employers in Delaware, the District of Columbia, Pennsylvania, and West Virginia; Maryland and Virginia have their own state workplace safety and health programs.
Safety controls typical in the warehousing industry include fire suppression, lockout/tagout procedures, machine guarding, means of egress, and forklift safety.
The Philadelphia region program targets the warehousing, storage, and distribution yard operations of the following industries:
- Bottled and canned soft drinks and water manufacturing;
- Fluid milk manufacturing;
- General warehousing and storage;
- Refrigerated warehousing and storage;
- Supermarkets and groceries; and
- Wholesale beer and ale, general line grocery, groceries and related products, and meat and meat products.
Regional compliance safety and health officers (CSHOs) also look to determine whether there are temporary workers at a facility. If so, CSHOs need all documentation and information about health and safety training programs offered to temporary workers at the facility. Host employers and staffing agencies are jointly responsible for ensuring the health and safety of temporary workers.
OSHA inspectors will also review powered industrial truck compliance, performing checks for hazards like stand-up forklift under-ride hazards, as well as vehicle maintenance, operation, practices, proper charging or fueling procedures, safety rule enforcement, and training.
Inspection procedures include checks of the following:
- Capacity and structural integrity of storage racks and the safe and stable storage of items;
- Fire suppression and means of egress, as detailed in the National Fire Protection Association’s (NFPA) Life Safety Code (NFPA 101-2009), which is incorporated by reference in several OSHA standards;
- Injury and illness recordkeeping and reporting compliance, including electronic reporting of injury and illness information;
- Lockout/tagout (hazardous energy control) procedures, with a check of records for injuries related to servicing and maintenance; and
- Ergonomic hazards (MSDs), hazardous chemical exposures, and heat hazards.
Your Warehouse Safety Compliance
The most frequently cited OSHA standards, after warehouse inspections, are those for forklifts (powered industrial trucks (29 Code of Federal Regulations (CFR) §1910.178), hazard communication (HazCom) (§1910.1200), obstructed exit routes (§1910.37), and material handling (§1910.176). However, you also should be mindful of the need for fall protection and walking-working surface safety in a warehouse or distribution center.
Forklifts
Forklifts can pose an injury hazard to their operators, as well as other workers in a facility. The powered industrial trucks standard is one of the agency’s most cited regulations. OSHA’s powered industrial trucks standard includes requirements for operator training and certification, safe forklift operation, 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.
Warehousing employers need to separate forklift traffic from other workers wherever possible, limiting some aisles to forklifts only or workers on foot only. 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
Your warehouse may also need a robust HazCom program to manage any chemical hazards. If a CSHO performing a safety inspection is aware of any hazardous substances present in your facility, 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 the host employer and the contract employer are responsible for HazCom compliance, and OSHA will cite both employers for any violations.
A program must include information and procedures for labels and other warnings, safety data sheets (SDSs), and employee training. An agency inspector will check for a written program, as well as evidence of all program elements. A CSHO will interview employees, managers, and supervisors to assess all aspects of workplace HazCom compliance—labels, SDSs, information, and training.
Exits and Exit Routes
OSHA regulations for exits and exit routes include the following requirements:
- Exit routes remain free of explosive or highly flammable furnishings and other decorations, and exit route doors must be free of decorations or signs that would obscure the visibility of the doors.
- If the direction of exit access and exit discharge isn’t immediately apparent, signs must indicate the proper direction of travel.
- Doors along the exit access that could be mistaken for exit doors must be marked “Not an Exit” or with a sign identifying their use, such as “Closet.”
- Exit routes must remain unobstructed by materials, equipment, locked doors, or dead-end corridors and have adequate lighting.
Slips, Trips, and Falls
Falls on the same level are a leading cause of DART cases, according to the National Safety Council (NSC). Injuries from falls on the same level include soreness or pain (in 26% of incidents); sprains, strains, and tears (24%); bruises and contusions (19%); and fractures (14%).
Housekeeping is key in maintaining safe walking-working surfaces. Recommended actions include:
- Immediately cleaning all spills;
- Mopping or sweeping debris from floors;
- Marking spills and wet areas;
- Removing obstacles from walkways and keeping walkways free of clutter;
- Covering any cables or cords that cross walkways; and
- Keeping working areas and walkways well lit and replacing faulty light switches and used light bulbs.
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.
Proper footwear can also help prevent slips, trips, and falls.
Falls to a lower level are a safety hazard in some warehouses. Last year, OSHA cited a multinational athletic apparel and shoemaker for failure to correct fall hazards at a Chester, New York, warehouse. The company was required to install guardrails or equivalent protection for employees accessing and working on a mezzanine and ensure ladders used to access the mezzanine extend at least 3 feet (ft) above the landing. After citing the company in March 2022 following a 2021 inspection, agency inspectors returned in 2024 to find the company hadn’t corrected its violations.
Material Handling
Manual material handling poses a risk for worker MSDs. Employer resources include the National Institute for Occupational Safety and Health’s (NIOSH) Ergonomic Guidelines for Manual Material Handling. The institute’s guidance covers ergonomic interventions that can lower the physical demands of manual material-handling tasks.
Steps you can take to lower workers’ risks include decreasing the forces required in lifting, handling, pushing, and pulling materials. Risk factors include the following:
- Awkward postures, such as bending and twisting;
- Repetitive motions, such as frequent reaching, lifting, and carrying;
- Forceful exertions, like carrying or lifting heavy loads;
- Pressure points—grasping loads, leaning against parts, or surfaces that are hard or have sharp edges; and
- Static postures—maintaining fixed positions for a long time.
Identifying MSD risks in material handling will involve reviewing injury and illness logs, observing work activities, and using assessment tools, like NIOSH’s Manual Material Handling Checklist and Hazard Evaluation Checklist for Lifting, Pushing, or Pulling; the NIOSH Lifting Equation; and the American Conference of Governmental Industrial Hygienists’ (ACGIH) Threshold Limit Values (TLVs) for Manual Lifting.
Ongoing OSHA Enforcement
Under OSHA’s NEP, agency inspectors conduct comprehensive safety inspections focused on hazards related to powered industrial vehicle operations (forklifts), material handling and storage, walking-working surfaces, means of egress, and fire protection, as well as warehouse heat and ergonomic hazards.