OSHA has renewed its National Emphasis Program (NEP) targeting warehousing and distribution center operations, signaling that employers in these industries should expect continued scrutiny of workplace safety practices. The revised directive, CPL 03-00-026, became effective July 31, 2026, and will remain in effect for five years.
The program covers warehousing and distribution centers, certain U.S. Postal Service processing and distribution centers, courier and express delivery services, local delivery operations, and several categories of warehousing and storage. OSHA will conduct comprehensive safety inspections at establishments selected under the NEP rather than inspections limited to a single hazard or complaint.
OSHA identifies several recurring hazards as areas of particular concern, including powered industrial vehicles, materials handling and storage, walking-working surfaces, means of egress, heat, ergonomics, and fire protection.
The agency’s rationale rests heavily on injury statistics. OSHA reports that during the first 18 months of the original warehouse NEP, inspectors identified more than 1,700 violations and removed approximately 37,410 workers from hazardous conditions. The warehousing and storage workforce also more than doubled between December 2015 and December 2025, increasing from approximately 882,100 to more than 1.8 million employees.
The injury data remains significant. For 2020 through 2024, all private industry averaged a recordable case rate of 2.6 and a DART rate of 1.6. General warehousing and storage recorded rates of 5.2 and 4.4, respectively. Couriers and express delivery services reported even higher rates of 8.6 and 6.9.
The 2026 version makes several notable changes. OSHA removed high-injury-rate retail establishments from the program and eliminated mandatory screening requirements for ergonomic and heat hazards. Those hazards, however, have not disappeared from OSHA’s enforcement focus. Area Offices retain discretion to expand inspections arising from fatalities, catastrophes, complaints, or referrals to address hazards such as heat and ergonomics.
Employers should also expect inspectors to look closely at recordkeeping. During the opening conference, OSHA will verify the establishment’s NAICS code and employee count and review OSHA 300 logs, 300A summaries, and 301 incident reports for the current and previous three calendar years.
For construction material suppliers, roofing distributors, and other businesses operating warehouse and distribution facilities, the key threshold will be the establishment’s NAICS classification. The NEP specifically limits inspections under the program to the listed warehouse, courier, delivery, and postal classifications.
👉 Takeaway: Employers covered by the warehouse NEP should treat an OSHA inspection as a foreseeable event rather than a remote possibility. Now is the time to audit forklift operations, material storage, walking-working surfaces, emergency exits, fire protection, heat procedures, ergonomics, and OSHA recordkeeping. Equally important, employers should train managers on what to do when OSHA arrives. With comprehensive inspections authorized under the program, a compliance officer entering the facility for one apparent concern may examine substantially more than the condition that initially drew OSHA’s attention.
