OSHA Renews Warehouse National Emphasis Program Through 2031

WASHINGTON — A compliance officer can still walk a warehouse dock under a national program through 2031. OSHA’s revised National Emphasis Program for warehousing and distribution-center operations took effect July 31, 2026, and expires five years from that date. The document is OSHA Instruction CPL-03-00-026, signed July 6, 2026, by David L. Keeling, Assistant Secretary.

The useful change is not the title. It is what the officer no longer has to do on every visit, and which buildings are still in the book. Retail is out. Heat and ergonomics stay in scope, but they are no longer a mandatory screen on every inspection. A site that thinks the program ended in 2023 is reading the old page.

Casters and carts that live on those floors: plate-mount casters · made-in-USA oak dollies · flatbed carts. OSHA does not name them. The walking surface does.

What the directive covers

The instruction covers safety inspections of warehousing and distribution-center operations, mail and postal processing and distribution centers, and parcel delivery and courier services. OSHA says inspections focus on powered industrial vehicle operations, material handling and storage, walking-working surfaces, means of egress, heat, ergonomics, and fire protection.

Read that list as the aisle, not the brand. A forklift path. A pallet that has sat too long. A trailer dock in July. A floor that no longer drains. A caster is not a cited object in the directive. A wheel that will not swivel, a missing brake, or a cart left in an egress can still become part of a walking-surface or material-handling finding. That is a floor condition, not a product endorsement.

The 2026 instruction supersedes the warehousing NEP that took effect July 13, 2023. It uses the same directive number. New inspections are coded WAREHOUSE. Inspections still being finished under the previous program stay coded WAREHOUSE23.

What changed from 2023

• Removed coverage for high-injury-rate retail establishments. A store floor is no longer in this program because the warehouse behind it is.
• Removed mandatory screening for ergonomic and heat hazards. Those hazards stay in scope. Screening is no longer required on every inspection. An officer can still open them. The officer does not have to start there.
• Extended the expiration to five years from the effective date. The PDF does not print “July 31, 2031.”
• Clarified Area Office discretion to expand inspections after fatalities, catastrophes, complaints, or referrals in the covered NAICS codes.
• Changed program coding to “WAREHOUSE.”

Who is still in the book

Table 2 of the directive lists these NAICS codes:

• 491110 — Postal Service, processing and distribution centers only
• 492110 — Couriers and express delivery services
• 492210 — Local messengers and local delivery
• 493110 — General warehousing and storage
• 493120 — Refrigerated warehousing and storage
• 493130 — Farm product warehousing and storage
• 493190 — Other warehousing and storage

A compliance officer may inspect under this NEP only if the establishment’s NAICS code is in Table 2. Inspections do not include postal or package delivery to homes and businesses. A post office that is not a processing and distribution center is not covered. A last-mile van is not this program. OSHA also says not to open an inspection under this NEP if the site had a comprehensive safety inspection of these hazards within the previous three years.

The rates that explain why the program exists

OSHA says warehousing and storage employment rose from 882,100 in December 2015 to 1,836,200 in December 2025. The sector roughly doubled in a decade. More people, more docks, more of the same hazards. In the first 18 months of the 2023 NEP, the agency says it identified more than 1,700 violations and removed approximately 37,410 workers from hazards. Those figures are the directive’s, not an independent audit.

Table 1 prints 2020–2024 five-year average incidence rates (recordable case rate / DART rate). All private industry sits at 2.6 / 1.6. Couriers and express delivery sit at 8.6 / 6.9. General warehousing is 5.2 / 4.4. That gap is the argument for the program, printed in the instruction itself:

• All private industry: 2.6 / 1.6
• Postal processing and distribution (491110): 5.3 / 4.9
• Couriers and express delivery (492110): 8.6 / 6.9
• Local messengers and local delivery (492210): 6.1 / 4.9
• General warehousing and storage (493110): 5.2 / 4.4
• Refrigerated warehousing (493120): 4.6 / 3.8
• Farm product warehousing (493130): 3.2 / 2.6
• Other warehousing and storage (493190): 3.1 / 2.5

A plant manager does not need a lawyer to use the table. If the building’s code is on it, the program can still reach the dock. If it is not, this NEP is the wrong document. Either way, the PDF is the text. The HTML landing page still showed a 2023 date and an archive banner the day this was drafted.

State plans

State Plans must submit a notice of intent within 60 days of the effective date saying whether they will adopt the update or already have a warehousing emphasis program at least as effective. OSHA encourages adoption. It does not require it. If a state adopts, OSHA says that should be done within six months. A Texas warehouse and a California warehouse are not automatically on the same clock.

What a caster house can usefully say

The directive does not specify a wheel. It does inspect the floor those wheels run on. CasterHQ is a Mansfield, Texas caster house. It manufactures made-in-USA oak carts and dollies, and it is a master dealer and stocking warehouse for names including Colson, Albion, and Hamilton, built for short lead times and the specification call that follows a bad wheel on a live aisle. Plate-mount casters are at plate-mount casters. Oak dollies and wood carts are at H-frame oak dollies and flatbed carts and platform trucks. This article reports the OSHA directive. It is not legal advice, and it does not claim any caster is named in it.