Warehouses and distribution centers are complex workplaces. Powered industrial trucks move alongside pedestrians, employees manually handle materials throughout a shift, products are stacked vertically in racking systems, trailers are loaded and unloaded, emergency exits must remain accessible, and production demands can change dramatically from one day to the next. Add summer heat, repetitive work, automated equipment, temporary employees, and tight delivery schedules, and the warehouse becomes an environment where multiple hazards can interact at the same time.
That complexity is receiving renewed attention from the Occupational Safety and Health Administration. OSHA’s updated National Emphasis Program on Warehousing and Distribution Center Operations, Directive CPL-03-00-026, became effective July 31, 2026. The program applies OSHA-wide and covers warehousing and distribution center operations, mail and postal processing and distribution centers, and parcel delivery and courier services. OSHA describes inspections conducted under the program as comprehensive safety inspections focused on hazards common to these industries.
The renewed program is also intended to remain in effect for five years rather than the three-year duration of the previous initiative. OSHA has specifically highlighted powered industrial truck operations, material handling and storage, walking-working surfaces, means of egress, heat, ergonomic risks, and fire protection and prevention among the hazards addressed through the program.
For employers, the message should not simply be, “OSHA might inspect us.” The more important question is whether these same hazards are being effectively managed every day.
Why Warehousing Deserves a Systems Approach
OSHA identifies some of the most common warehouse injuries as musculoskeletal disorders associated with lifting and lowering materials and injuries involving powered industrial trucks and other material-handling equipment. The agency also identifies chemical exposures, slips, trips and falls, ergonomics, and newer hazards associated with automation and robotics among the risks warehouse employers should consider.
What makes warehouse safety particularly challenging is that these hazards rarely operate independently. Consider a forklift traveling through a busy warehouse. The obvious hazard is the powered industrial truck, but preventing an incident involves much more than training the operator. Pedestrian routes, aisle width, visibility at intersections, storage practices, floor conditions, lighting, production flow, trailer activity, and employee behavior can all influence the likelihood of an incident.
The same principle applies to material handling. An employee experiencing back or shoulder pain may initially appear to present an ergonomic issue, but the underlying conditions may include pallet height, product weight, picking frequency, staffing, production expectations, equipment availability, and workstation design.
Strong warehouse risk management therefore requires more than a collection of independent safety programs. Employers need to understand how people, equipment, processes, and operational expectations interact.
Powered Industrial Trucks: Look Beyond Operator Certification
Forklifts are one of the most recognizable warehouse hazards, and operator training and certification are essential. However, an effective powered industrial truck program should extend well beyond confirming that operators have training cards. Employers should examine how forklifts actually move through the facility.
- Where do pedestrians and forklifts interact? Are there blind intersections?
- Are mirrors, barriers, signs, gates, or other controls appropriate?
- Are employees routinely walking through forklift travel lanes because the facility layout makes another route inconvenient?
- Are trailers properly secured during loading and unloading?
- Are operators wearing seat belts and performing required inspections?
- Are damaged trucks actually removed from service?
Traffic management is ultimately a system-design issue. An excellent forklift operator still has limited ability to prevent an incident if pedestrians unexpectedly enter blind intersections or if storage practices obstruct visibility.
This is also an area where observation matters. Rather than reviewing only training records, supervisors and safety professionals should periodically spend time watching normal forklift and pedestrian movement. The objective should be to understand where conflicts occur before one of those conflicts becomes an injury.
Material Storage: What Is Above Your Employees Matters
Warehouses are designed to use vertical space efficiently, which means significant quantities of material may be stored above employees and equipment. Damaged racking, unstable loads, overloaded storage systems, and improperly stacked materials can create serious struck-by and collapse hazards.
OSHA recommends inspecting and maintaining shelving and racking, isolating damaged areas when necessary, protecting rack uprights from incidental forklift contact, maintaining load capacities, placing heavier materials on lower or middle shelves, and ensuring stored materials are stable and secure.
One particularly important practice is developing a process for responding to rack damage. Forklift impacts happen. The critical question is what happens afterward. If an upright is struck, do employees know how to report it? Is the area evaluated? Does someone with appropriate knowledge determine whether the rack remains safe? Is damaged equipment repaired or replaced?
Warehouse inspections should therefore involve looking upward as well as at floor level. Bent uprights, damaged cross members, displaced loads, leaning pallets, broken decking, and materials protruding into aisles can all provide early warning that storage practices need attention.
Walking-Working Surfaces and Egress: Ordinary Conditions Can Create Serious Risk
Housekeeping is sometimes treated as one of the simplest areas of safety, but warehouse housekeeping has significant implications. Stretch wrap, broken pallets, packaging material, damaged flooring, cords, leaking equipment, and products temporarily placed in aisles can create slip and trip hazards. The same operational pressure that causes material to accumulate in an aisle can also interfere with emergency egress.
Emergency exits and exit routes need to remain accessible when they are needed, not simply when someone conducts an inspection.
Employers should look at whether material gradually migrates into aisles and exit routes during busy periods. An exit route that is clear at 7:00 a.m. may look very different during peak production several hours later. This is why one-time inspections provide only part of the picture.
A more useful approach is to observe conditions during different shifts, production levels, and operating circumstances. Risk changes as the operation changes.
Ergonomics: The Hazard May Be Built Into the Job
Warehousing is physically demanding work. Employees may repeatedly lift, lower, carry, push, pull, bend, reach, twist, and handle products throughout a shift. OSHA identifies these activities as ergonomic risk factors that can contribute to musculoskeletal disorders affecting the back, shoulders, wrists, and other parts of the body.
Ergonomic risk management should not begin and end with telling employees to “lift with their legs.” Training has value, but job design frequently has a much greater influence on exposure.
Employers should examine where products are positioned, how frequently employees handle them, how much they weigh, how far employees reach, and whether mechanical assistance is practical. OSHA’s warehouse guidance discusses measures such as adjusting pallet heights, reducing case weights, providing access around pallets, using mechanical stretch wrappers, improving forklift seating and vibration control, and considering job rotation or work-rest cycles where appropriate.
The best ergonomic assessment often begins by watching employees work. Where are people struggling? Which tasks cause employees to shake out their hands or stretch their backs? Where are workers improvising because the equipment does not fit the task? Those observations can reveal exposures that injury records have not yet captured.
Heat Does Not Stop at the Warehouse Door
Heat is sometimes considered primarily an outdoor construction concern, but warehouses can become significant indoor heat environments, particularly when facilities are not climate controlled, employees perform strenuous physical work, or heat-generating equipment contributes to environmental conditions.
OSHA identifies warehousing among the indoor industries where workers may experience hazardous heat exposure. Occupational risk factors include physical activity, hot conditions, lack of acclimatization, and clothing that retains body heat.
OSHA’s warehouse guidance recommends measures such as providing drinking water, rest opportunities and cooler areas, improving ventilation, training employees to recognize heat illness, monitoring workers for signs of illness, and gradually acclimatizing new or returning employees to hot conditions.
Heat also deserves additional attention in 2026 because OSHA has a separate National Emphasis Program for Outdoor and Indoor Heat-Related Hazards, updated in April 2026. Employers should therefore treat heat as an occupational exposure requiring planning rather than simply telling employees to drink more water when temperatures rise.
Fire Protection and Emergency Preparedness Need Operational Attention
Warehouses can contain enormous fuel loads. Cardboard, packaging materials, pallets, plastics, chemicals, batteries, and stored products can all affect fire risk. Storage arrangements can also interfere with fire protection systems or emergency movement when they are poorly managed.
Employers should routinely evaluate whether fire extinguishers and emergency equipment remain accessible, exit routes are clear, storage practices are compatible with fire protection requirements, and employees understand what is expected during an emergency.
The key word is routinely. Warehouse configurations can change quickly. A storage location that was acceptable when the facility was originally designed may no longer be appropriate after product lines, rack configurations, or production volumes change.
Emergency preparedness should evolve with the operation.
Automation and Robotics Are Changing Warehouse Risk
Modern warehouses increasingly use conveyors, automated pallet wrappers, robotics, automated guided vehicles, and other technology to improve productivity. These systems can reduce certain manual exposures, but they can also introduce new struck-by, caught-between, electrical, and hazardous-energy concerns.
OSHA specifically identifies automation and robotics as an emerging warehouse safety consideration and notes that automated tools must be properly integrated into the workplace to protect workers.
The risk can become particularly significant during maintenance, troubleshooting, cleaning, jam clearing, or other nonroutine work. Equipment that is highly automated during normal production may require employees to enter hazardous areas when something goes wrong.
That means automation should trigger a broader risk-management discussion involving machine guarding, lockout/tagout, employee access, sensors and interlocks, maintenance procedures, training, and emergency response.
Technology may change the hazard, but it does not eliminate the need to manage risk.
What Would OSHA See If It Walked Into Your Facility?
The renewed National Emphasis Program provides employers with an opportunity to look at their operations through a different lens. Instead of waiting for an inspection, management teams can conduct their own focused review.
Begin with powered industrial trucks and traffic flow. Observe where equipment and pedestrians interact rather than reviewing only certification records. Examine storage racks and materials for damage, instability, overloading, or evidence of repeated forklift contact. Walk aisles and emergency exit routes during actual production, not only during quiet periods. Observe material-handling tasks and ask employees where they experience physical strain. Evaluate indoor heat conditions and the controls available to workers. Review fire protection and emergency preparedness. Finally, examine how automation, conveyors, robotics, and other equipment are controlled when employees perform nonroutine work.
Most importantly, involve employees in the review.
Ask workers where they believe someone could realistically get hurt. Ask forklift operators which intersections concern them. Ask order pickers which products are difficult to handle. Ask maintenance employees which automated systems are difficult to isolate. Ask supervisors what changes when production demand spikes.
These conversations turn an inspection exercise into a risk assessment.
Move From Finding Hazards to Managing Them
Identifying hazards is only the first step. A warehouse can complete dozens of inspections and still have a weak safety system if identified problems remain unresolved.
A practical approach is to use a simple four-step process: identify, fix, verify, and protect.
Identification means finding the hazard through inspections, employee reports, observations, near misses, or other sources. Fixing means assigning responsibility and implementing an appropriate control based on the level of risk. Verification means returning afterward to determine whether the corrective action actually solved the problem rather than simply closing an item on a spreadsheet. Protection means incorporating what was learned into the larger system so the same condition does not quietly return.
Consider a blind forklift intersection. Installing a mirror may appear to correct the issue, but verification requires observing whether the mirror actually provides adequate visibility and whether employees use it. A stronger review may reveal that pedestrian traffic should be physically separated instead.
Corrective action should reduce risk, not simply complete paperwork.
Use OSHA’s Renewed Focus as an Opportunity
An OSHA National Emphasis Program understandably gets employers’ attention because it increases awareness of enforcement activity. That is useful, but inspection preparation should not be the ultimate objective.
The more valuable opportunity is to examine why OSHA continues to find significant hazards in these operations and determine whether similar conditions exist in our own workplaces.
Warehouse risk is dynamic. Products move, employees move, equipment moves, and operational demands change throughout the day. Effective safety programs have to be equally dynamic. They need employees who report concerns, supervisors who recognize changing conditions, leaders who provide resources for corrective action, and systems that verify whether controls continue to work.
The renewed Warehousing and Distribution Center National Emphasis Program gives employers a clear indication of where OSHA believes serious workplace risks continue to exist. It also provides a useful framework for evaluating our own operations.
Do not begin by asking whether your warehouse could pass an OSHA inspection. Begin by walking the operation with the people who work there and asking a more important question: Where could someone realistically get hurt today, and what are we going to do about it?
That is the difference between preparing for an inspection and managing risk.
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