The Occupational Safety and Health Administration (OSHA) recently renewed its National Emphasis Program (NEP) for warehouses and distribution centers.
The new NEP replaces the agency’s July 13, 2023, directive. Significant changes in the new directive include:
- Removing coverage of high-injury-rate retail establishments;
- Removing mandatory screening requirements for ergonomic and heat hazards;
- Extending the NEP’s expiration date to five years from the July 31 effective date;
- Clarifying area offices’ discretion to expand inspections based on fatalities/catastrophes, complaints, or referrals related to establishments in the North American Industry Classification System (NAICS) codes covered under the NEP; and
- Changing the OSHA Information System (OIS) code to “WAREHOUSE.”
According to an August 6 announcement on OSHA’s website, under the renewed NEP, the agency will conduct comprehensive inspections focused on common warehousing and distribution industry hazards that include:
- Powered industrial truck (forklift) operations;
- Material handling and storage;
- Walking-working surfaces and slip, trip, and fall hazards;
- Means of egress and emergency exits; and
- Fire protection and prevention.
During an inspection based on fatalities/catastrophes, complaints, or referrals at warehouses and distribution centers, an OSHA Area Office may expand an inspection to address workplace hazards common to the warehouse and distribution industry, such as powered industrial vehicle operations, material handling/storage, walking-working surfaces, means of egress, heat, ergonomics, and fire protection. According to the agency, the updated NEP provides greater continuity in OSHA’s enforcement efforts.
The industries targeted under the NEP and their NAICS industry codes are:
- Postal Service (Processing and Distribution Centers only) (NAICS 491110)
- Couriers and Express Delivery Services (492110)
- Local Messengers and Local Delivery (492210)
- General Warehousing and Storage (493110)
- Refrigerated Warehousing and Storage (493120)
- Farm Product Warehousing and Storage (493130)
- Other Warehousing and Storage (493190)
According to insurer Liberty Mutual, the top four causes of workplace injuries in transportation and warehousing are overexertion involving outside sources (handling materials), falls on the same level (slips, trips, and falls), awkward postures (“other exertions or body reactions”), and falls to a lower level. Overexertion alone accounts for nearly a third of employers’ costs each year, totaling $1.45 billion.
Warehousing Hazards, Frequently Cited Standards
The OSHA standards most frequently cited in warehouses address some of the more obvious warehouse safety hazards, such as forklifts, hazard communication (HazCom), obstructed exit routes, and material handling.
Some of the agency’s most frequently cited standards in warehouse inspections include:
- Powered industrial trucks (29 Code of Federal Regulations (CFR) §1910.178);
- Maintenance, safeguards, and operational features for exit routes (§1910.37);
- HazCom (§1910.1200);
- Portable fire extinguishers (§1910.157); and
- Handling materials (§1910.176).
Forklift Compliance
Forklifts can pose an injury hazard to their operators and other workers in a facility.
Operators must wear a safety belt or restraint if the forklift is equipped with one. Fatal forklift incidents can involve the overturning of a forklift, workers’ being struck by a forklift, workers’ being 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. Flashing lights may be the best way to alert others to a forklift’s presence in environments with high ambient noise.
Forklift operators must be trained and licensed. NIOSH recommends that employers develop a training program with a timetable for refresher training. Employers also need to regularly reevaluate their training programs.
Operators should stay with the truck if a lateral or longitudinal tipover occurs, hold on firmly, and lean away from the point of impact.
Warehousing and storage employers need to separate forklift traffic from other workers whenever possible, limiting some aisles to forklifts only or workers on foot only. Also restrict forklift use near time clocks, break rooms, cafeterias, and main exits, particularly when foot traffic is at a peak, such as 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.
Forklift operators should never exceed the forklift’s rated load and never lift or lower loads while traveling. They must also be aware of other vehicles, watch for workers on foot, and use their horns at cross aisles and in areas with obstructed views. Additionally, they need clear visibility into the work area and sufficient clearance when raising, loading, and operating the forklift.
Any forklifts or other powered industrial trucks in your facility must meet industry consensus standards, and your compliance program needs to address operator training—only trained and authorized operators may be permitted to operate a powered industrial truck. Unauthorized personnel must be prohibited from riding on powered industrial trucks.
The OSHA standard also contains requirements for vehicle operation, maintenance, and repair, including battery changing or charging and fueling powered industrial trucks.
The storage and handling of liquid fuels must meet the requirements of the National Fire Protection Association’s (NFPA) standard for Liquefied Petroleum Gases (NFPA 58). Personnel who fuel your industrial trucks must be instructed not to fill fuel tanks while the engine is running. The use of open flames to check gasoline levels in fuel tanks or electrolyte levels in storage batteries must also be prohibited.
Fuel or oil spills must be carefully washed away or completely evaporated and the fuel tank cap replaced before restarting the engine.
The repair of industrial truck fuel and ignition systems that may involve fire hazards must only be conducted in locations designated for such repairs. The battery must be disconnected before making repairs to a truck’s electrical system. Following repairs, an industrial truck must be examined before being returned to service.
HazCom—Worker ‘Right to Know’
Warehouses that store or distribute hazardous chemicals will also 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 a HazCom investigation. If a compliance safety and health officer (CSHO) is aware of the presence of hazardous substances, the officer will look for a written HazCom program covering all employees who may be exposed. At a multiemployer worksite, such as a warehouse staffed by employees of a logistics company, both the host and the contract employer are responsible for HazCom compliance, and OSHA may cite both for violations.
The program must include information and procedures for labels and other warnings, safety data sheets (SDSs), and employee training.
A CSHO will assess how a contractor’s employees access SDSs for substances on-site and how they’re informed of and trained on chemical hazards in the workplace and the necessary precautions for those 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.
Exit Routes
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 aren’t 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 employees won’t 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
- Adequate lighting along exit routes for employees with normal vision.
Portable Fire Extinguishers
OSHA’s portable fire extinguisher standard covers the placement, use, maintenance, and testing of portable fire extinguishers provided for employees’ use. Employers must only use approved portable fire extinguishers and locate, mount, and identify them so they’re readily accessible to employees. They must also ensure portable fire extinguishers are maintained, fully charged, operating properly, and always kept in their designated places except during their use.
They must also train those employees designated in the emergency action plan to use firefighting equipment in proper use of portable fire extinguishers.
Material Handling
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 to keep stacks stable and secure against sliding or collapse.
Storage areas must be kept free of accumulations of materials that could pose 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, loading docks, and doorways and wherever turns or passage is required. 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 (MSDs). Employer resources include NIOSH’s Ergonomic Guidelines for Manual Material Handling.
The American Industrial Hygiene Association (AIHA) has an acronym “W-H-A-T PACE” to remind employers of the factors in material-handling hazards:
- Weight: The heavier the object, the higher the risk of overexertion.
- Handling ease: Loads with contents likely to move, loads that can’t be carried close to the body, or loads without handles all increase the risks of MSDs.
- Awkward postures, such as bending, kneeling, reaching, stooping, and twisting, increase risk.
- Time/distance: Loads that must be carried a greater distance or for a longer time are higher risk.
- PACE: The number of loads that must be moved per shift.
OSHA’s inspection and enforcement will continue to focus on warehousing and storage employers for another five years.