On July 31, 2026, the Occupational Safety and Health Administration (OSHA) renewed its warehousing national emphasis program (NEP), which had expired on July 13, 2026. While the renewed NEP narrows certain aspects of the prior program, it continues to authorize comprehensive safety inspections for covered establishments, focusing on areas OSHA has identified as hazards.
The New Program
The new NEP covers businesses in seven NAICS (North American Industry Classification System) codes.
- Postal Service processing and distribution centers (NAICS 491110)
- Couriers and Express Delivery Services (NAICS 492110)
- Local Messengers and Local Delivery (NAICS 492210)
- General Warehousing and Storage (NAICS 493110)
- Refrigerated Warehousing and Storage (NAICS 493120)
- Farm Product Warehousing and Storage (NAICS 493130)
- Other Warehousing and Storage (NAICS 493190)
Businesses in five NAICS codes that were included in the previous program have been removed from the 2026 program.
- Home Centers (NAICS 444110)
- Hardware Stores (NAICS 444130)
- Other Building Material Dealers (NAICS 444190)
- Supermarkets and Other Grocery (except Convenience) Stores (NAICS 445110)
- Warehouse Clubs and Supercenters (NAICS 452311)
Other changes include:
- Term – The NEP is in effect for five years, until July 31, 2031, with a program review within four years.
- No Mandatory Screening – The mandatory heat and ergonomic screening that was part of the previous program has been removed.
- Unfinished Business – OSHA Area Offices have been told that they are not required to complete unfinished cycles from the 2023 program.
- OIS Code – Changed to “WAREHOUSE.” Prior inspections coded WAREHOUSE23.
Considerations
If you have not done so already, employers are advised to determine whether their business falls within one of the seven covered NAICS classifications that are the focus of the renewed NEP. These classifications were also a focus of the previous NEP. Larger, multiple-facility businesses should not rely solely on the entity’s primary NAICS code. When multiple facilities are involved, consider a location-by-location review of operations at each site, and then verify each establishment’s NAICS code, total number of employees, and the location where warehousing or distribution activities are performed. Do not assume that a corporate-wide classification determines your NEP risk exposure.
While mandatory heat screening is no longer required, heat-related concerns remain in the document. The revised NEP has kept heat among the hazards that an inspection will focus upon, and heat remains governed by its own separate directive, which OSHA reissued in April 2026.
If you are on the target list, you should prepare for a comprehensive inspection, with particular attention on the areas that OSHA has identified as workplace hazards common to the targeted workplaces. These hazards include powered industrial trucks and associated traffic management, material handling/storage, walking-working surfaces and fall hazards, means of egress and exit routes, heat-related hazards, ergonomic hazards, and fire protection. Consider a compliance review in all these areas.
During an inspection, you can expect the compliance officer to scrutinize injury and illness records. Make sure your OSHA 300 Logs, 300A Summaries, and 301 Incident Reports are up to date and readily retrievable — for the current and previous three calendar years. It is a good idea to review these records prior to an inspection and identify any injury trends that a compliance officer will question.
Finally, as others have noted, the NEP includes a contradictory directive for State Plan jurisdictions. The section title is “Notice of Intent Required, Adoption Required.” The text immediately following the title states that State Plans are “strongly encouraged, but are not required, to adopt” the updated requirements of the NEP. Employers operating in State Plan states should review with counsel and confirm how that state plans to implement the renewed NEP. Do not assume that this federal directive will apply immediately without some adjustments.
Questions?
If you have any questions or concerns about these changes to the warehousing NEP and your readiness for an OSHA inspection — or if you have received a citation for any reason — don’t hesitate to contact Orr & Reno for assistance.
