OSHA Extends Warehouse Inspection Program Through July 2031
OSHA’s revised National Emphasis Program for warehouses and distribution centers is active nationwide and will remain in effect through July 31, 2031. The program directs comprehensive safety inspections at covered operations, giving employers a reason to review records, equipment and hazard controls now.
The directive, OSHA Instruction CPL-03-00-026, was signed July 6, 2026, and became effective July 31, 2026. It replaces the prior version that took effect July 13, 2023. OSHA says inspections under the renewed program began July 31.
The National Emphasis Program is an inspection and enforcement-prioritization directive, not a new standalone nationwide safety standard. It does not mean every covered warehouse will be inspected or that the directive automatically creates new duties for every employer. Instead, it tells OSHA offices which covered industries and hazards should receive focused attention.
What changed
The revised program extends the emphasis period from three years to five years. Because the new directive took effect July 31, 2026, its stated expiration date is July 31, 2031.
OSHA also removed the prior category for high-injury-rate retail establishments. That change narrows this particular emphasis program; it does not broadly exempt retail businesses from OSHA inspections or other enforcement.
The revised directive also removes mandatory screening requirements for heat and ergonomic hazards. Both hazards remain listed among the program’s inspection priorities, but inspectors are no longer required to screen for them during every covered inspection.
Finally, the directive clarifies when an OSHA area office may expand an inspection. Complaints, referrals, fatalities or catastrophes involving a covered establishment may lead the office to examine additional warehouse-related hazards when the available facts indicate that broader violations could be present.
Which operations are covered
The program applies OSHA-wide to specific industry categories, including general, refrigerated, farm-product and other warehousing and storage operations. It also covers postal processing and distribution centers, courier and express delivery services, and local messenger and local delivery operations.
The directive identifies these covered categories through NAICS codes 491110, 492110, 492210, 493110, 493120, 493130 and 493190. Inspections under this NEP do not include postal or package transportation and delivery to residences and businesses.
Employers should also check whether their workplace is covered by an OSHA-approved State Plan. State Plans must be at least as effective as the federal program, but they may adopt different or more stringent requirements. OSHA’s directive says states are encouraged to adopt the updated program and must indicate their intent within 60 days of the effective date; adoption may occur on a different timetable and is not identical in every state.
What OSHA may examine
Inspections under the program are comprehensive safety inspections. Priority areas include powered industrial vehicles such as forklifts; material handling and storage; walking-working surfaces, including slips, trips and falls; means of egress and emergency exits; heat; ergonomics; and fire protection.
During an inspection, OSHA says its compliance officers will verify the establishment’s industry classification and review OSHA Forms 300, 300A and 301 for the current and previous three calendar years. The review is intended to identify recorded injuries and illnesses associated with hazards covered by the program.
What employers should review now
Warehouse and distribution managers should confirm their operation’s NAICS classification and determine whether it falls within the revised program. They should also check that inspection-ready records are complete and consistent with internal incident and near-miss reports.
- Forklift and powered-industrial-vehicle training, authorization and maintenance records
- Storage racks, load limits, aisle clearance and material-handling procedures
- Walking surfaces, housekeeping and blocked-aisle controls
- Exit routes, emergency plans and fire-protection systems
- Heat controls, hydration and break procedures, even though mandatory screening was removed
- Ergonomic assessments and corrective actions for lifting, reaching and repetitive work
- Hazard assessments, employee training and documented corrective actions
- Maintenance records, incident investigations and near-miss reports
Employers should document what was corrected, when the correction was made and who verified it. A clean recordkeeping process matters because OSHA’s inspection procedures allow officers to compare logs, incident reports, employee statements and conditions observed in plain view.
How inspections may begin or expand
For programmed inspections, OSHA will use neutral and objective targeting methods to select establishments within the covered NAICS categories. Area offices may work from randomized master lists or inspection cycles rather than scheduling every covered facility.
Separate unprogrammed inspections may begin because of a complaint, referral, fatality or catastrophe. The revised directive also allows an area office to expand a programmed or unprogrammed inspection when evidence indicates that violative conditions may be present and the establishment is covered by the NEP.
That means the program should be treated as an ongoing management priority, not as an automatic inspection date for every warehouse.
Why OSHA is continuing the focus
OSHA said agency and Bureau of Labor Statistics data show that the covered industries have had injury and illness rates above the average for all private industries. The directive reports that warehousing and storage employment more than doubled from 882,100 workers in December 2015 to 1,836,200 in December 2025, using seasonally adjusted BLS figures.
OSHA also reported that during the first 18 months of the prior emphasis program it identified more than 1,700 violations and removed approximately 37,410 workers from hazards. Those figures are agency-reported results from the prior program, not a forecast of what the revised program will produce.
For employers, the immediate task is practical: verify coverage, reconcile safety records, document corrections and address hazards that workers and inspectors could see on the warehouse floor. The revised program does not create a new national safety rule, but it signals that OSHA will continue directing inspection resources toward covered operations through July 31, 2031.
Sources
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