Warehouse safety gates, guardrail systems, travel restraint systems, personal fall arrest systems, and other warehouse fall protection systems are critical. The warehousing and storage industry has an injury rate nearly double the national average. It stands at 4.8 injuries per 100 workers against all private industries’ 2.7 injuries per 100 workers.
The rapid growth of eCommerce over the past couple of years has fueled an ongoing expansion of the warehousing and storage industry. This means the number of workers facing these hazardous conditions keeps rising daily.
To reduce injury rates and improve industrial safety, OSHA announced a new Regional Emphasis Program on August 3, 2022. Among many things, the REP instructs compliance officers how to conduct comprehensive inspections that address indoor fall hazards unique to the warehousing and storage industry.
This guide discusses the REP’s details and what it means for warehouses.
What is OSHA’s Regional Emphasis Program (REP)?
OSHA’s REP is an instruction that establishes strategies and policies that inspectors must follow when scheduling and conducting inspections of warehousing, storage, and distribution yard operations in targeted North American Industry Classification System codes (NAICS).
It is limited to warehouses and storage and distribution yards in the District of Columbia, Pennsylvania, Maryland, Virginia, Delaware, and West Virginia.
The goal of OSHA’s REP is to reduce injury rates by addressing hazards associated with life safety, lockout tagout, powered industrial trucks, fire suppression, and means of egress.
Though announced on August 3, 2022, the first three months were for education and prevention, during which agency officials share health and industrial safety information with relevant stakeholders. The inspections began around early November 2022. It ends August 3, 2027, unless extended.
What Should You Expect in an Inspection Under the OSHA REP?
Before showing up at the site, OSHA inspectors usually do their homework, which involves researching the worksite’s inspection history, assessing the processes and operations an organization uses, and the standards highly likely to apply at that workplace.
It’s rare for OSHA to give an advance notice of inspection. In actual fact, it’s illegal for OSHA inspectors to provide an advance notice of an upcoming OSHA inspection, according to OSHA 1903.6(c). It’s on rare occasions that OSHA inspectors can offer a notice, i.e.,
- In instances of impending danger,
- When the OSHA inspection is scheduled to occur after business hours,
- When special preparations are to be made,
- If it’s unlikely worker representatives or managers will be present on site during the inspection.
Once an OSHA inspector arrives at the site, the compliance officer will:
- Obtain all information on temporary workers, such as information for evaluating their industrial safety and health programs and whether the employer has provided a safe workplace for them according to OSHA’s regulations.
- Inspect whether the employer complies with the powered industrial truck standard 29 CFR 1910.178 in training, maintenance, etc.
- Evaluate the structural integrity, safe storage, and other indoor fall hazards
- Inspect hazards relating to fire suppression and means of egress
- Review compliance with 29 CFR §1910.147.
- Review the site’s injury records for compliance with 29 CFR 1904
The inspector will also check for ergonomic hazards, heat hazards, and hazardous chemical exposures.
What does the OSHA REP Mean for Your Organization?
OSHA typically conducts on-site inspections under very specific criteria, such as an employee complaint or report of imminent danger. However, with the new OSHA REP, OSHA can conduct assessments based on the NAICS Code. So, you can be selected randomly for an inspection because you operate in a certain industry, even if your record is spotless.
When the compliance officer is scheduling the emphasis program inspection, they are likely to combine it with other inspections, especially if they were already planned, such as the Heat Illness National Emphasis Program (NEP).
Likewise, if they come to conduct an on-site inspection prompted by, say, an employee complaint, they are likely to expand it to include the areas covered in the REP.
The increased number and breadth of inspections increase the likelihood of more cited violations on other industrial safety hazards, particularly indoor fall hazards.
You must take a proactive approach to address not just the areas covered by the REP but also ensure that your workers are protected from falls with warehouse safety gates and rails in all dangerous places, such as ladders, stairwells, mezzanines, loading docks, etc. The warehouse safety gates and other safety systems must comply with OSHA regulations.
OSHA Regulations on Warehouse Fall Protection
According to OSHA 1910.28, you must implement fall protection and prevention measures around holes, hoist areas, dock boards, runways, and unprotected edges at least four feet higher than a lower level. Some of the OSHA-compliant features and equipment you can use include:
- Warehouse safety gates;
- Guardrail systems;
- Safety net systems;
- Travel restraint systems; or
- Personal fall arrest systems.
OSHA compliant safety gates are especially important in the warehousing and storage industry. They come in various designs and styles to satisfy most operational needs, such as preventing falls, ensuring the safe movement of vehicles and pedestrians, and protecting valuable equipment. They provide a fast, easy, and scalable installation, can fit any size, application, or budget, and comply with OSHA regulations.
Eliminate Indoor Fall Hazards with Fabenco
OSHA’s Regional Emphasis Program aims to reduce injuries and illnesses in the warehousing and storage industry. This means the number of inspections in the targeted NAICS is likely to increase, and their breadth will likely broaden. You must take a proactive approach to avoid the fines and jail time imposed on those who violate OSHA regulations. You must study all OSHA regulations and implement the necessary changes to ensure you are compliant and your workers are safe.
If you need industrial safety gates, contact Fabenco, a leading manufacturer of fall protection products like safety gates for over 45 years. We offer a wide array of OSHA compliant safety gates and custom models to meet the specific needs of any facility. We can help keep your employees stay safe and your organization stay compliant with ever evolving OSHA regulations.
