OSHA Renewed Its Warehouse Inspection Program Through 2031
OSHA replaced its 2023 warehousing emphasis program on July 31, 2026 and reset the clock to 2031. Two things came out of it, and the trade coverage is getting both of them wrong.
On July 31, 2026, OSHA replaced the warehousing National Emphasis Program it had been running since July 2023 with a revised directive carrying the same number, CPL 03-00-026. The program was due to lapse. It didn't. It now runs five years from its effective date, which puts it in place until the summer of 2031.
Two provisions came out of the 2023 version, and both are being reported in ways that overstate what happened. Here is what the directive actually says.
What the program is
An NEP is how OSHA decides where to send inspectors when nobody has called in a complaint. Under this one, every inspection is a comprehensive safety inspection — not a walk to the corner of the building someone complained about, but a full-facility review.
The directive names the hazards those inspections focus on: powered industrial vehicle operations, material handling and storage, walking-working surfaces, means of egress, heat, ergonomics, and fire protection. That list is "including, but not limited to," so it sets the floor rather than the ceiling.
Coverage runs by NAICS code: 493110, 493120, 493130 and 493190 on the warehousing side, plus couriers, local delivery, and USPS processing centers.
The justification is in the directive's own table. Across 2020–2024, BLS five-year averages put all private industry at 2.6 recordable cases and 1.6 DART per 100 workers; general warehousing runs 5.2 and 4.4, couriers 8.6 and 6.9. OSHA also reports more than 1,700 violations in the 2023 program's first 18 months.
Three things changed
High-injury-rate retail establishments are out. The 2023 version swept in a table of retail operations alongside warehousing. That table is gone. If you run a distribution operation this changes nothing; if you were watching this program because of a retail footprint, it no longer reaches you.
Mandatory screening for ergonomic and heat hazards is out — and this is the one worth reading carefully. Under the 2023 program, an inspector arriving on an NEP inspection was required to screen for both. That requirement has been removed. What has not happened is heat and ergonomics dropping off the list: both are still named in the directive as hazards these comprehensive inspections focus on. The screening step became discretionary; the subject matter did not go away.
It has no bearing on heat enforcement generally, which runs on its own track: OSHA reissued the heat-related hazards NEP (CPL 03-00-024) in April 2026, also for five years. Reading "OSHA dropped heat" into this directive would be an expensive mistake heading into next summer.
Area Offices have clarified discretion to expand. If OSHA arrives on a fatality, catastrophe, complaint, or referral at a covered establishment, the Area Office may expand that visit to cover the NEP hazard list. In practice this is the provision most likely to affect a smaller operator: you are far more likely to meet this program through something that brought an inspector to your door than through a programmed inspection.
How a facility gets picked
For programmed inspections, OSHA's Office of Statistical Analysis generates a Master List of establishments in the covered NAICS codes for each Area Office, assigns every establishment a random number, and sorts by it. Area Offices work that list straight through, in random order, or in cycles — a subset of ten, say, finished before the next begins.
The mechanism is worth understanding for what it rules out. Selection is random within the covered codes. It is not driven by your injury history, your size, or anything you did. A clean record does not remove you from the list.
What inspectors actually cite
The directive says what OSHA is looking for. OSHA's citation data says what it finds. For NAICS 493110 in fiscal 2025 — October 2024 through September 2025 — the most-cited standards in general warehousing were:
| Standard | Subject | Citations |
|---|---|---|
| 1910.178 | Powered industrial trucks | 169 |
| 1910.1200 | Hazard communication | 65 |
| 1910.37 | Exit routes — maintenance and safeguards | 39 |
| 5(a)(1) | General Duty Clause | 30 |
| 1910.157 | Portable fire extinguishers | 29 |
| 1910.303 | Electrical, general | 28 |
Forklifts are not close to the rest. One standard accounts for more citations than the next three combined, and 1910.178 is largely a documentation standard in practice — operator evaluations on file, refresher training after an incident, certification naming the specific truck type. Those are records, and records are what an inspector can check in ten minutes.
What to do about it
Nothing here requires a new program. It changes where inspectors go and what they look at when they arrive, and the preparation is what it was in July:
Pull your powered industrial truck files and confirm every operator has a current evaluation naming the equipment they actually run. Walk your exit routes and check that nothing is stored in them — that is 39 citations' worth of a problem that takes an afternoon to fix. Confirm your hazard communication inventory matches what is actually on the shelf.
Keep whatever you built for heat and ergonomics. The screening requirement was never the reason to have them.
For what each standard actually requires, the complete guide to OSHA warehouse safety standards is the reference. If your state runs its own OSHA program, the directive requires state plans to give notice of intent and adopt — so this reaches you on your state's timetable, not the federal one.
This post summarizes publicly available regulatory information. Compliance requirements vary by jurisdiction, operation size, and other factors. Consult legal counsel for guidance specific to your facility.