OSHA’s latest National Emphasis Program (NEP) is targeting warehousing and distribution center operations, mail/postal processing and distribution centers, parcel delivery/courier services and certain retail stores with high injury rates.

An NEP is a temporary inspection emphasis based on a particular hazard that is typically targeted to specific NAICS codes where certain hazards are most prevalent or in safety areas showing a trend towards high hazards.  NEP inspections can be scheduled on their own, or OSHA can tack one on at an inspection if they see something that applies. So, if OSHA is onsite to investigate a complaint and they see something that could fall under an NEP, they can inspect for that too while they are there.

Who’s Covered in this NEP and Why?

OSHA recognizes a warehousing and distribution growth boom and an increased DART rate compared to other industries.  In 2011 there were 668,900 warehousing and distribution centers, and in 2021 that number was 1,713,900.  DART rates and total recordables for the industries covered in this NEP were over twice that of all private industry, some were more than three times the private industry rate from 2017-2021.

These are the NAICS Codes that will fall under the NEP:

  • 491110 Postal Service (Processing & Distribution Centers only)
  • 492110 Couriers and Express Delivery Services
  • 492210 Local Messengers and Local Delivery
  • 493110 General Warehousing and Storage
  • 493120 Refrigerated Warehousing and Storage
  • 493130 Farm Product Warehousing and Storage
  • 493190 Other Warehousing and Storage

The following warehouse-type retail stores are included because they have been found to have issues in loading and storage areas and have higher than average DART (Days Away; Restricted; Transfer) rates:

  • 444110 Home Centers
  • 444130 Hardware Stores
  • 444190 Other Building Material Dealers
  • 445110 Supermarkets and Other Grocery Stores
  • 452311 Warehouse Clubs and Supercenters

This retail list will change each calendar year based on which related establishments have the highest DART rates.

What Will Inspectors Look For?

Inspectors will be looking at these program areas:

  • Powered Industrial Vehicles (already an emphasis program in several regions)
  • Material Handling and Storage
  • Walking-Working Surfaces
  • Means of Egress
  • Fire Protection
  • Heat (already a National Emphasis Program)
  • Ergonomic Hazards

For heat, inspectors will review injury and illness records, ask about it during worker interviews, and look for these in the walkthrough.  If inspectors see exposures to heat-related hazards or if they find your NAICS code already falls under the Heat NEP, they will expand the scope of the inspection to include the Heat NEP.   Read more about what that inspection entails here.  Heat is a big emphasis right now with OSHA because it helps them meet their responsibilities in complying with the Presidential directive on climate change.

If inspectors see ergonomic hazards in their reviews of records, worker interviews and the walkthrough, they can also expand the scope to ergonomics and open a health inspection in addition to the safety inspection.

Read the full NEP documentation here.

Questions?  Need Assistance?

iSi can help answer questions you may have about this NEP or any others, as well as conduct a mock OSHA inspection to see where you stand if OSHA were to conduct this inspection at your facility today.  Contact us!

Need Help?

Need an extra hand to get your safety issues covered? How about policies/programs developed or training conducted?


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