Effective last week, the Occupational Safety and Health Administration’s (OSHA) Region 3 Administrator, whose jurisdiction covers PA, DE, MD, VA, WV, and Washington DC, released a Regional Emphasis Program (REP) for Warehousing Operation which seeks to reduce injury/illness rates in the warehousing industry by conducting comprehensive inspections to address hazards that may include those associated with powered industrial trucks, lockout/tagout, life safety, means of egress and fire suppression.

The REP applies to warehousing, storage, and distribution yard operations in Region 3. The REP will not be applied to marine terminals or shipyards, and is set to expire in five years, unless renewed. According to the release, the incident rate for industries covered by the REP, including warehousing and storage, food and beverage stores, and grocery wholesalers, is higher than the incident rate for all private industry.

The REP projects that OSHA will conduct programmed inspections, which are inspections scheduled based upon objective or neutral selection criteria, as well as unprogrammed inspections, such as inspections conducted in response to reports of imminent dangers, complaints, or referrals. Unprogrammed inspections, the REP notes, may be conducted without regard to the subject establishment being on the current cycle for programmed inspection. Employers impacted by the REP should prepare for these inspections.

Ballard Spahr’s Labor & Employment Group regularly advises employers on health and safety compliance at the federal, state and local levels and is prepared to help employers respond to OSHA’s new guidance.