OSHA National Emphasis Programs 2026: Target Industries and Inspection Timing
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OSHA National Emphasis Programs 2026: Target Industries and Inspection Timing

OSHA's National Emphasis Programs in 2026 target specific manufacturing and warehousing sectors for intensive inspection. Learn which programs are active, which are expiring, and what to prepare for.

by iSi Environmental

The calendar year 2026 marks a transition point in OSHA’s enforcement landscape for manufacturers and industrial operators. Two major National Emphasis Programs are expiring this year while a third has just locked in a five-year renewal. Understanding which enforcement programs remain active and which are winding down is critical for facilities that have built compliance programs around them — and equally critical for facilities that have deferred safety improvements because they assumed elevated enforcement risk would persist.

⚡ TL;DR: OSHA’s Heat NEP expired April 8, 2026 but was renewed April 10 with updated targeting (55 industries, NWS heat advisory triggers). The Warehousing NEP expires July 13, 2026 with no announced renewal. The five-year Amputations NEP (manufacturing machinery, fabricated metals, printing) runs through June 27, 2030. Two ongoing indefinite NEPs: Combustible Dust and Respirable Crystalline Silica. Manufacturing facilities should assess which NEPs apply to their operations and prioritize compliance before renewal expirations or while five-year programs remain active.

National Emphasis Programs (NEPs) are OSHA’s enforcement directives that concentrate inspection resources on specific hazards or high-hazard industries. They are not new regulations — they are prioritization tools that authorize compliance officers to conduct unprogrammed (unannounced) inspections targeting specific hazard categories. When an NEP is active, your facility faces a meaningfully higher probability of an unannounced inspection than facilities outside the program’s scope. When an NEP expires, that elevated risk drops unless renewed by OSHA administration.

⚠️ The Pain Frame: Manufacturing facilities operating under multiple active NEPs face compounding inspection risk. A machinery manufacturing facility (Amputations NEP), food processing operation (Heat NEP), and warehousing distribution center (Warehousing NEP through July) could each see unannounced inspections in the same 12-month period. OSHA compliance officers expand scope when they discover hazards — a heat inspection that uncovers fall protection deficiencies expands into Fall Protection citations. Facilities in multiple NEP categories without comprehensive hazard controls face penalty exposure of $100,000–$300,000 across a single year if inspected in each relevant program. The distinction between facilities that weather multiple NEPs with zero violations vs. facilities facing $150,000+ in settlement is documentation, training, and systematic hazard control.

Five NEPs currently affect manufacturing and industrial operations. Here is their status as of April 2026 and what each one means for your facility’s compliance strategy.

Which OSHA Inspection Programs Are Ending in 2026?

Heat-Related Hazards NEP — Expired April 8, 2026

The National Emphasis Program on Outdoor and Indoor Heat-Related Hazards expired April 8, 2026. This program had authorized proactive inspections whenever the heat index reached 80°F or when the National Weather Service issued heat warnings or advisories. It covered 70+ high-risk industries including construction, agriculture, food processing, landscaping, restaurants, and outdoor retail operations.

Two days later, on April 10, 2026, OSHA issued a completely revised version of the directive — renewing the program with a narrowed industry list (55 targeted industries, down from 70+) and replacing the 80°F heat index trigger with National Weather Service heat advisory/warning triggers. The renewed program runs through approximately 2031. See our detailed analysis of the Heat NEP renewal for the full breakdown of what changed.

What this means: If your facility operates in one of the 55 targeted industries — including food processing, foundry/metalcasting, plastics manufacturing, and warehoused goods manufacturing — programmed heat inspections will resume when NWS heat advisories are issued for your area. The renewed program is more targeted but still very much active. Facilities not on the 55-industry list see reduced programmed inspection risk, but OSHA’s general duty clause still applies and worker complaints still trigger investigations.

Warehousing and Distribution Centers NEP — Expires July 13, 2026

The Warehousing and Distribution Centers NEP expires July 13, 2026. This program has authorized wall-to-wall inspections at warehousing and storage facilities — not targeted hazard inspections, but comprehensive reviews of the entire operation from receiving dock to shipping bay.

Why did OSHA create this program? Employment in warehousing and storage grew from 668,900 to 1,713,900 workers between 2011 and 2021 — a 156% increase. The industry’s DART (Days Away, Restricted or Transferred) rate runs 2.5 to 3.0 times higher than all private industry combined. That injury rate prompted the NEP’s creation and has not improved since.

OSHA has not announced a renewal of this program. Facilities in SIC 42 (Warehousing and Storage) have approximately three months under the elevated wall-to-wall inspection risk. The violations that triggered the most citations under this NEP remain compliance risks regardless:

  • 1910.178 — Forklift operator certification failures
  • Blocked exit routes and inadequate fall protection
  • Ergonomic hazards from material handling and prolonged standing

These hazards trigger citations under any complaint investigation. Use the remaining window to close the gaps before the NEP expires — not because the NEP is expiring, but because the compliance obligation is permanent.

What Powered Industrial Vehicle Operators Must Demonstrate Before July 13

Under the warehousing NEP’s focus on powered industrial vehicle (PIV) safety, OSHA compliance officers are documenting forklift operator certification status with precision. The standard is clear: 29 CFR 1910.178 requires all PIV operators to be trained, evaluated, and licensed.

What OSHA inspectors are finding: operators working without current certifications, trainers providing certifications without documented evaluation, and operations substituting informal “on-the-job training” for actual operator training and testing.

Before the NEP expires:

  • Verify every forklift operator has current certification documentation
  • Confirm the training records identify the specific equipment trained on (Class 1, Class 2, Class 3, etc.)
  • Ensure evaluation documentation shows the operator was tested — not just trained
  • Schedule refresher training for operators whose last certification is more than three years old

The Five-Year Amputations NEP: Active Through 2030

The National Emphasis Program on Amputations in Manufacturing Industries was renewed June 27, 2025, and runs through June 27, 2030. This is a five-year enforcement commitment, not a one-year extension dependent on budget cycles. Administration changes and OSHA funding negotiations do not alter this scheduled duration.

The 2025 renewal also expanded the program’s scope. Coverage now extends beyond the original high-risk SIC codes to include any manufacturing industry with elevated OSHA Information System inspection counts, high Bureau of Labor Statistics amputation data, or high employer-reported amputation rates.

Primary target industries under the Amputations NEP:

  • SIC 35 — Machinery Manufacturing — Assembly machines, punch presses, metal stamping equipment
  • SIC 34 — Fabricated Metal Products — Metal shearing, cutting, and forming
  • SIC 27 — Printing and Publishing — Printing presses and bindery equipment
  • SIC 28 — Chemical and Allied Products — Chemical reactors and mixing equipment
  • SIC 24 — Lumber and Wood Products — Woodworking machinery, saws
  • SIC 26 — Paper and Allied Products — Paper mills and converting equipment
  • SIC 25 — Furniture and Fixtures
  • SIC 32 — Stone, Clay, and Glass Products

If your facility falls in these SIC codes, NEP inspections are not a 2026 concern — they are a 2026 through 2030 reality. Programmed inspections are authorized and will occur. Small establishments with 10 or fewer employees classified as “low-hazard” under the Appropriations Act Directive are excluded from these programmed inspections, but complaint-triggered investigations are not excluded regardless of size.

What Do OSHA Inspectors Look for Under the Amputations Program?

The inspection focus is predictable, which means the compliance response can be systematic.

Machine Guarding — The Primary Citation Category

29 CFR 1910.212 — General Machine Guarding — is the most frequently cited standard under this NEP. Every machine with a point of operation presenting an amputation hazard must be guarded. Compliance officers evaluate whether guards are in place, effective, and the appropriate type for the specific hazard.

What OSHA is finding: guards workers have learned to bypass or remove, guards installed but not used during normal operation, and hazard assessments that failed to identify all amputation-risk point-of-operation hazards. A guard workers routinely defeat is not a guard — it is evidence of the hazard, not control of it.

Lockout/Tagout Implementation — The Secondary Citation Category

29 CFR 1910.147 — The Control of Hazardous Energy (Lockout/Tagout) — is the second most frequent citation category. Energy control procedures must exist for every machine requiring servicing or maintenance. Inspectors request the written LOTO program, review machine-specific procedures, and evaluate whether workers can demonstrate actual competency.

The gap that generates citations: LOTO binders sitting in the safety office while shop floor practice diverges from documented procedures. Workers trained years ago without refresher documentation. Supervisors unable to demonstrate they supervise LOTO procedures. A LOTO binder that workers have not reviewed recently is not a defense — it is evidence that the program is not being implemented.

The penalty structure: Serious violations at $16,550 per violation. Willful violations at $165,514 per violation. NEP violations are typically cited as serious. Facilities with prior NEP citations for the same hazards face repeat violation exposure at the willful rate.

Two Ongoing NEPs Manufacturing Often Overlooks

Combustible Dust NEP — Active Indefinitely

The Combustible Dust NEP (CPL 03-00-008) is active with no expiration date. OSHA conducts approximately 600 inspections annually under this program. Target industries include:

  • Food and grain processing (flour mills, sugar plants, grain elevators)
  • Chemical manufacturing (dry chemicals, pigments)
  • Plastics and foam manufacturing
  • Textile mills (synthetic fiber operations)
  • Metal fabrication (aluminum and magnesium powder operations)
  • Pharmaceutical manufacturing
  • Rubber and tire manufacturing

Combustible dust explosions have historically caused catastrophic fatalities and property destruction. OSHA treats this hazard with indefinite enforcement focus for good reason.

Respirable Crystalline Silica NEP — Active with Mandatory Regional Allocation

The Respirable Crystalline Silica NEP (CPL 03-00-023) is active with each OSHA regional office required to allocate a minimum 2% of annual inspection activity to silica-covered industries. Target operations include sandblasting, concrete cutting and sawing, masonry work, grinding and polishing, foundry operations, and silica mining and processing. This NEP runs alongside the silica permissible exposure limit enforcement that has been in place since 2017 — it is not winding down.

What Should Your Facility Do Now?

For manufacturing facilities in the SIC codes covered by the Amputations NEP and facilities in sectors with ongoing programs:

Conduct a self-audit of machine guarding before an OSHA inspector does. Walk every machine in your facility with the Amputations NEP in mind. Document whether guards are in place, whether they are being used during normal operation, and whether LOTO procedures exist and are current for each piece of equipment. Machines presenting amputation hazards without adequate guarding are exactly what the NEP directs inspectors to find.

Verify LOTO documentation and field implementation match. Machine-specific procedures must be written, current, accessible, and actually followed. Supervisor observation of actual LOTO implementation during routine maintenance is the only way to verify this gap is closed. Inspectors will ask workers what the LOTO procedure is — and if the workers cannot answer, the violation is documented.

Update and document employee training records. Inspectors request training documentation. Records showing machine-specific training, operator sign-offs, and dates are the documentary foundation of your defense against citations. Records showing training was assigned but not completed, or completed years ago without refresher training, are not a defense — they are an additional citation item.

Do not treat NEP expirations as signals to defer maintenance. OSHA complaint investigations for machine guarding, heat illness hazards, and warehousing safety occur regardless of NEP status. Worker complaints about obvious safety deficiencies trigger the same enforcement outcomes as NEP inspections — just without the broader scope.

💰 Dollar Anchor: A machinery manufacturing facility (SIC 35, Amputations NEP active through 2030) currently operating without documented machine guarding or current LOTO procedures faces a likely inspection scenario: OSHA arrives, walks the floor, sees unguarded amputation points and inadequate energy control procedures. Typical outcome: 4–6 serious violations across machine guarding and LOTO, settlement $75,000–$150,000. Same facility with documented guarding assessment, guards in place, written LOTO procedures, current supervisor training, and current worker training records: typical outcome zero violations, inspection concludes with commendation. The cost of getting programs in place before inspection is $15,000–$30,000. The cost difference is $60,000–$120,000+. Facilities in five-year programs (Amputations NEP through 2030) should prioritize this work now.

Preparing for NEP Inspections: The Professional Approach

iSi Environmental’s industrial hygiene and safety consulting team conducts pre-inspection readiness assessments specifically for manufacturers in NEP target industries. For facilities in machinery manufacturing, fabricated metals, printing, and paper industries, a third-party machine guarding and LOTO audit before OSHA arrives produces a fundamentally different outcome than responding to citations after they are issued.

A readiness assessment identifies specific guarding deficiencies, documents LOTO procedure gaps, and verifies training documentation is current. The assessment positions your facility to either correct violations before inspection or present documented evidence of a compliance program to OSHA if an inspection occurs. Either path is dramatically better than discovering violations during an unannounced inspection.

We Plug In. You Level Up.

Frequently Asked Questions

Q: What is the difference between an NEP expiration and an ongoing indefinite NEP?

A: NEPs with expiration dates (Heat, Warehousing) represent temporary enforcement focus determined by available budget and administrative priorities. When they expire, programmed inspection authority ends for those hazard categories — though complaint investigations still occur. Indefinite NEPs (Combustible Dust, Respirable Crystalline Silica) represent permanent enforcement commitment. Facilities subject to indefinite NEPs should assume continuous elevated inspection risk and build permanent compliance programs, not temporary measures.

Q: If the Warehousing NEP expires July 13, 2026, can OSHA still inspect our facility after that?

A: Yes, absolutely. NEP expiration means the end of programmed wall-to-wall inspection authority for warehousing-specific hazards. But OSHA can still conduct complaint-triggered inspections, respond to fatality reports, and cite hazards discovered during any other inspection. Additionally, powered industrial vehicle training failures, ergonomic hazards, and fall protection deficiencies exist under permanent standards regardless of NEP status. NEP expiration is not a signal that compliance obligations have ended — it’s only a signal that programmed inspection activity for that specific program may decrease.

Q: Our facility is in SIC 35 (machinery manufacturing). The Amputations NEP runs through 2030. Can we expect an inspection?

A: Yes, facilities in Amputations NEP target industries should assume elevated inspection probability during the program’s five-year run. OSHA allocates resources to these sectors. However, facilities with documented machine guarding, current LOTO procedures, and training records are lower inspection priorities than facilities without such documentation. Build your compliance infrastructure based on expectations of inspection probability, and you’ll either prevent inspections entirely or resolve them favorably if they occur.

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