OSHA Directive CPL-03-00-026 took effect on July 31, 2026. It renews the National Emphasis Program (NEP) on Warehousing and Distribution Center Operations and replaces the version issued in 2023. The renewed program runs through July 31, 2031 unless OSHA modifies or cancels it earlier.

The directive does not create a new OSHA standard. It tells OSHA area offices where to direct inspection resources and how to conduct those inspections under standards that already exist. The inspection scheduling code changed from WAREHOUSE23 to WAREHOUSE.

What a National Emphasis Program is

A National Emphasis Program is an internal enforcement directive. It names a set of industries, then instructs area offices to schedule programmed inspections at establishments in those industries and to inspect a defined list of hazards when they arrive.

Two consequences follow for a covered facility:

  • An inspection can be opened without a complaint, an injury, or an elevated injury rate at that site.
  • Citations issued during the inspection are written under existing standards, such as powered industrial trucks, walking-working surfaces, means of egress, or the General Duty Clause.

Changes from the 2023 directive

Item 2023 NEP CPL-03-00-026 (2026)
Program duration Three years Five years, through July 31, 2031
High-injury-rate retail establishments In scope, including warehouse clubs, supercenters, and home centers Removed from scope
Heat and ergonomic hazard screening Mandatory during NEP inspections No longer mandatory; both remain listed inspection focus areas
Complaint, referral, fatality, and catastrophe inspections Expansion procedures less specific Expansion procedures clarified
Scheduling code WAREHOUSE23 WAREHOUSE

OSHA states the renewal is intended to produce greater continuity and consistency in enforcement. The removal of retail narrows the program back to core warehousing, postal, courier, and delivery classifications.

Which establishments are covered

The directive applies to seven NAICS codes:

  • 491110 Postal service processing and distribution
  • 492110 Courier 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 manufacturing site with an on-site distribution operation is not automatically covered. Coverage follows the establishment's NAICS classification. OSHA verifies the NAICS code, the employee count, and the warehouse location as part of its inspection procedures.

How a facility gets selected

Programmed inspections are scheduled using what the directive describes as neutral and objective criteria. A recent complaint, a significant injury, or an above-average injury rate is not a prerequisite for selection.

An inspection can also begin from a complaint, a referral, a fatality, or a catastrophe. In those cases the 2026 directive sets out when the inspection may be expanded into a full NEP inspection covering the program's hazard list rather than remaining limited to the reported condition.

Hazards and records examined

Inspection focus areas named in the directive:

  • Powered industrial vehicles, including forklift and pedestrian interactions
  • Material handling and storage, including storage systems and loading docks
  • Walking-working surfaces
  • Means of egress and emergency exits
  • Fire protection
  • Heat hazards
  • Ergonomic hazards

Inspectors review OSHA 300 Logs, 300A Annual Summaries, and 301 Incident Reports for the current year plus the three prior calendar years. A facility that cannot produce four years of complete records should expect that gap to be identified during the inspection.

Heat and ergonomics after the screening change

Removing the mandatory screening requirement changes when a compliance officer must look at heat and ergonomic conditions. It does not remove OSHA's authority to investigate them. Both remain listed focus areas, and OSHA retains authority to pursue them where evidence warrants.

Musculoskeletal disorders from overexertion during lifting and lowering are among the most common warehouse injuries. Facilities that treated the 2023 mandatory screening as the reason to maintain ergonomic assessments will find the underlying exposure unchanged. The same applies to heat: a facility without a written heat illness response protocol has the same exposure it had before July 31, 2026.

The American Society of Safety Professionals emphasises point-of-work verification over documentation.

Strong EHS performance cannot be separated from daily operations. Strong written programs are important, but what matters most is whether safeguards are understood, implemented and effective where the work is performed.

American Society of Safety Professionals
As cited in coverage of the renewed NEP, ASSP

Why OSHA extended the program

5.2
Recordable injury rate
Cases per 100 full-time workers in covered industries, 2020 to 2024, against a national average of 2.6
4.4
DART rate
Days away, restricted, or transferred, against a national average of 1.6
1,836,200
Warehousing employment, Dec 2025
Up from 882,100 in December 2015
1,700+
Violations identified
First 18 months of the original 2023 program
37,410
Workers removed from hazards
Approximate figure from the same 18-month period

The directive states that warehousing and distribution center injury and illness rates continue to be higher than baseline private general industry rates. The five-year term, twice the length of the 2023 program, indicates a longer enforcement horizon than the original directive set.

What to verify before an inspector arrives

  • Confirm the establishment's NAICS code

    If it is one of the seven listed codes, the site can be selected for a programmed inspection with no triggering event.

  • Assemble 300 Logs, 300A summaries, and 301 reports

    Current year plus three prior calendar years, matching the documented lookback period.

  • Walk forklift and pedestrian routes

    Powered industrial vehicle operation is the first named focus area in the directive.

  • Inspect racking, storage systems, and loading docks

    Material handling and storage remains a comprehensive inspection element.

  • Check every marked exit and egress path

    Means of egress and fire protection are separate focus areas from walking-working surfaces.

  • Keep heat and ergonomic controls in place

    Screening is no longer mandatory, but both hazards remain within inspection scope. Overlooked exposures of this kind are covered in more depth among the [subtle risks managers miss](/5-hidden-workplace-hazards-managers-miss/).

Key takeaways

  • CPL-03-00-026 is effective July 31, 2026 and expires July 31, 2031 unless modified earlier. The full directive is published on OSHA's enforcement directives site.
  • High-injury-rate retail establishments are out of scope. Seven warehousing, postal, courier, and delivery NAICS codes remain in scope.
  • Mandatory heat and ergonomic screening is gone. Enforcement authority over both hazards is not.
  • No new standard was created. Citations come from existing standards.

One point is not settled by the available reporting: the directive clarifies when a complaint, referral, fatality, or catastrophe inspection may be expanded into a full NEP inspection, but the specific expansion thresholds have not been detailed in the secondary coverage published since the effective date.