Cotney Breaks Down OSHA's Renewed Warehouse NEP

OSHA has renewed its National Emphasis Program (NEP) for warehousing and distribution centers. In a recent article on The Cotney Brief, Adams & Reese Partner and Construction Team Leader Trent Cotney explains what the revised five-year directive (CPL 03-00-026, effective July 31, 2026) means for employers.

Scope of the Program

The NEP covers warehousing and distribution centers, U.S. Postal Service processing facilities, courier and express delivery services, and local delivery operations. OSHA will conduct comprehensive safety inspections rather than inspections limited to a single hazard or complaint.

Hazards in Focus

Target hazards include powered industrial vehicles, materials handling and storage, walking-working surfaces, means of egress, heat, ergonomics, and fire protection. Cotney notes that while the 2026 version removed mandatory screening for ergonomic and heat hazards, area offices retain discretion to expand inspections to cover those issues.

The Numbers Behind the Program

During the first 18 months of the original NEP, OSHA identified more than 1,700 violations and removed roughly 37,410 workers from hazardous conditions. The warehouse workforce has more than doubled over the past decade to over 1.8 million employees, and injury rates remain well above average. General warehousing recorded a recordable case rate of 5.2 and a DART rate of 4.4 (2020-2024), compared with all-industry averages of 2.6 and 1.6. Couriers and express delivery reported even higher rates of 8.6 and 6.9.

Recordkeeping Will Be a Priority

Employers should also expect scrutiny of recordkeeping. During the opening conference, OSHA will verify NAICS codes and employee counts and review 300 logs, 300A summaries, and 301 incident reports for the current and previous three calendar years.

What Employers Should Do Now

Cotney advises treating an OSHA inspection as a foreseeable event. Key action items:

• Audit physical workplace conditions, including forklift operations, material handling and storage, walking-working surfaces, means of egress, and fire protection systems
• Review health and safety programs for heat illness prevention and ergonomics
• Verify OSHA recordkeeping, including 300 logs, 300A summaries, 301 incident reports, NAICS codes, and employee counts
• Train managers on OSHA inspection protocols so they know what to expect and how to respond when a compliance officer arrives

Under the program, a compliance officer entering a facility for one concern may examine far more than the issue that initially drew attention. For construction material suppliers, roofing distributors, and others operating warehouse facilities, coverage turns on the establishment's NAICS classification.

Read Cotney's full article here: OSHA Renews National Emphasis Program for Warehousing and Distribution Centers - Trent Cotney.