Warehousing

Hazards and Solutions

Warehouse workers face many hazards, but proper design, planning and training can keep them safe. These references can aid you in recognizing and controlling those hazards.

Warehousing industry workers may be exposed to ergonomic risk factors in the workplace, such as lifting and lowering heavy items, bending, reaching overhead, pushing and pulling heavy loads, working in awkward body postures, and performing the same or similar tasks repetitively. Exposure to these known risk factors increases workers’ risks of musculoskeletal disorders (MSDs), such as muscle strains, lower back and shoulder injuries, carpal tunnel syndrome, tendinitis, and others. associated with a fast work pace and/or the use of continuous performance monitoring systems can exacerbate MSDs. Ergonomics— the science of fitting jobs to people— helps lessen muscle fatigue, increases productivity, and reduces the number and severity of work-related MSDs.

The table below discusses different types of materials handling operations (i.e., receiving/shipping unit loads, case picking, and item picking) and associated MSD hazards and solutions.

Handling Materials Musculoskeletal Disorder (MSD) Hazards Solutions
Receiving unit loads (i.e., pallets, bins, large boxes, carpet and paper rolls).

Hazards in these operations are mainly related to the use of powered industrial trucks (PITs), and include:

  • Whole-body vibration from uneven floors
  • Dock shock from uneven transition to a truck trailer or rail car
  • Chronic neck pain from prolonged looking up to store units and looking back while driving in reverse.
  • Back disorders from prolonged sitting without lumbar support.
  • Conduct routine maintenance of PITs to reduce vibration from the vehicle.
  • Fill cracks in the floor and smooth transitions between areas.
  • Install and maintain dock levelers appropriate for the vehicles used in receiving and shipping.
  • Provide seats with adjustable lumbar support and vibration dampening.
  • Use a camera to assist with storage and retrieval of unit loads.
  • Use shorter loads to enable forward driving.
  • Minimize long travel distances while backwards.
Picking cases from a pallet or other unit load.

Cases weigh from a few pounds to over 100 pounds. As in unit load shipping and processing, workers in case picking operations are exposed to . Other risk factors include:

  • Overexertion sprains and strains to the back and shoulders from manually moving materials.
  • Wrist overexertion from prolonged awkward posture and force needed to operate the pallet jack throttle and stretch wrap orders.

In cold environments (e.g., refrigerated warehouses), exerting additional force and pressure to grip, lift, hold, and carry objects, which may exacerbate other MSD risk factors

  • Reduce case weights to 35 pounds or less.
  • For cases over 35 pounds, raise the pallet so cases can be lifted between the knees and mid chest.
  • Raise pallets used for order consolidation to reduce bending on the first layer.
  • Provide access to the 3 sides of the pallet for both floor stock and order consolidation pallets.
  • Place heavier cases on the bottom of an order and limit consolidated orders to shoulder height.
  • Use a mechanical stretch wrapper.
  • Develop job rotation and work/rest cycles to provide whole body and local muscle fatigue recovery.
  • Provide adequate warm time for workers in cold storage.
Picking individual items from a case for an order. As in unit and case picking, workers in item picking operations are exposed to . Workers consolidate orders then place them in a bag or box for shipping. These workers face repetitive hand, wrist and shoulder movements from high volume picking.
  • Place high volume times near standing elbow height.
  • Keep item weights under 10 pounds or 2 pounds when a pinch grip is used, and tote weights under 35 pounds.
  • Provide anti-fatigue mats or shoes that cushion and provide arch support.

The following provide additional information regarding ergonomics and musculoskeletal disorders:

  • Ergonomics. OSHA Safety and Health topic page dedicated to preventing injuries to workers from musculoskeletal disorders.
  • OSHA Technical Manual (OTM) Section VII: Chapter 1: Back Disorders and Injuries.
  • Grocery warehousing eTool. This eTool covers example ergonomic hazards and solutions specializing in traditional order picking.

Warehouses are a constant moving mix of people, vehicles and equipment. Forklift operators must be properly trained to ensure understanding of the working environment. This prevents injuries to operators and pedestrians and damage to other warehouse equipment (storage racks, stored materials, etc.).

Forklift Operations

  • Only trained and certified workers may operate a forklift. (See 29 CFR 1910.178). No one under the age of 18 may use a forklift.
  • Operators must be trained on the type of vehicle in use, and on workplace conditions.
  • Before operating the vehicle, examine it for hazardous conditions which would make it unsafe to operate.
  • Always wear a seatbelt, if available.
  • Never exceed the rated load and ensure it is stable and balanced.
  • Ensure you have enough clearance when raising, loading, and operating the vehicle.
  • Follow safe procedures for picking up, putting down and stacking loads.
  • Keep a safe distance from platform, ramp, and loading dock edges. Never back up a forklift to the dock’s edge.
  • Watch for pedestrians and observe the speed limit.
  • Slow down in congested areas and those with slippery surfaces.
  • Use horns at cross aisles and obstructed areas.
  • Do not give rides or use the forks to lift people.
  • If required to park a vehicle on an uneven surface, set the emergency brake.

Forklift Maintenance and Repair

  • Ensure vehicles are maintained and repaired in accordance with manufacturers’ recommendations.
  • Remove from service any forklift found to be in unsafe operating condition.
  • Do not modify or make additions to the forklift that could affect capacity and/or safe operation without prior written approval from the manufacturer.

Charging Stations

  • Properly position forklifts and apply brakes before attempting to change or charge batteries.
  • Ensure that fire extinguishers are available and fully charged.
  • Provide proper personal protective equipment such as rubber gloves and eye and face protection.
  • Provide conveyors, overhead hoists or equivalent materials handling equipment for servicing batteries.
  • Provide an eyewash and safety shower facility for workers exposed to battery acids.
  • Provide adequate ventilation to disperse fumes from gassing batteries.
  • Prohibit smoking and open flames in and around charging stations.

Other Considerations

  • Maintain safe clearances for aisles and at loading docks or passages.
  • Provide visual warnings near dock edges.
  • Follow required procedures when refueling gas or propane fueled forklifts.
  • Train workers on the hazards associated with the combustion byproducts of forklift operation, such as carbon monoxide.

Below are some resources to assist with powered industrial truck safety.

Safe storage and handling of material in warehouses is critical to preventing worker injury and property damage.

Storage and Handling

  • Inspect and maintain shelving and racking to prevent collapse. If damage occurs, immediately isolate the affected area.
  • Install rack upright guards to prevent damage from incidental forklift contact.
  • Ensure materials stored on racks, shelving, and other storage devices do not create a hazard.
  • Ensure bags, containers, bundles, etc. are stored in tiers that are stacked, blocked, interlocked and limited in height so that they are stable and secure to prevent sliding or collapse.
  • Properly stack loose/unboxed materials to prevent falling hazards.
  • Keep storage areas free from accumulation of materials that could lead to tripping, fires, explosions, or pest harborage.
  • Place heavier loads on lower or middle shelves.
  • Ensure that storage shelving and rack load capacities are not exceeded.
  • See , above, for materials handling hazards and solutions.

Conveyors

  • Inspect conveyors regularly.
  • Ensure that pinch points are adequately guarded.
  • Develop procedures for locking out conveyors when necessary (e.g., when materials have fallen off or become jammed), and training workers in these procedures.
  • Provide proper lighting and working surfaces in the area surrounding the conveyor.

Mechanical Handling Equipment

  • Provide periodic maintenance of pallet jacks and fork lifts so they can operate with the minimum amount of hand, arm, and finger force.
  • Ensure elevators and hoists for lifting materials are used with adequate safe clearances, no obstructions, appropriate signals, and directional warning signs.
  • Ensure sufficient safe clearances in aisles, at loading docks, through doorways, and wherever turns or passage must be made.
  • Mark boundaries of permanent aisles and passages where handling equipment is used to ensure proper clearance.
  • Keep aisles and passageways clean and unobstructed.
  • Keep floors well maintained (e.g. no ruts or bumps) to reduce force when using manual materials handling equipment and whole body vibration/shock from driven equipment.

Below are some OSHA resources that can assist in protecting workers from materials handling hazards:

Falls in the workplace continually show as a large injury producer. Warehousing environments are no exception and can present unique challenges because of the ever-changing environment, as products are loaded, unloaded, and moved around the warehouse. Employers should understand the legal requirements and best practices for preventing injuries and fatalities caused by slips, trips, and falls in the workplace.

General Considerations

  • Ensure that each worker on a walking-working surface with an unprotected side or edge that is 4 feet or more above a lower level is protected from falling.
  • Provide and ensure workers use head protection if they are exposed to falling object hazards. Additionally, barricade any area into which objects could fall and prohibit workers from entering the barricaded area.
  • Train workers on fall hazards in a language that they understand.
  • Train workers using ladder safety systems or personal fall arrest systems on their proper use, operation, maintenance, as well as proper methods of equipment inspection and storage.
  • Retrain workers when: (1) changes in the workplace render previous training obsolete or inadequate, (2) changes in the types of fall protection systems or equipment to be used render previous training obsolete or inadequate, or (3) when inadequacies in an affected worker's knowledge or use of fall protection systems or equipment indicate that the worker no longer has the requisite understanding or skill necessary to use equipment or perform the job safely.

Floors

  • Keep floors and aisles clear of clutter, electrical cords, hoses, spills, and other hazards that could cause slips, trips, or falls.
  • Where floors may be wet or slippery (e.g., due to high humidity, and/or the presence of ice or water), maintain good drainage and use grated floors, platforms, or rubber mats to provide a dry place for workers to stand while working.

Ladders

  • Inspect ladders to identify any visible defects that could cause injury. Remove any ladder with structural or other defects from service and tag it with "Dangerous: Do Not Use" or similar language.
  • Maintain “3 points of contact” when climbing up or down ladders and do not carry any object or load that could cause a loss of balance or fall while climbing up or down the ladder.
  • Use portable ladders only on stable and level surfaces unless they are secured or stabilized to prevent accidental displacement.
  • Do not move, shift, or extend any portable ladder while in use.
  • Guard portable ladders with a temporary barricade or secure the ladders to prevent accidental displacement when the portable ladder is placed in a location such as a passageway, doorway, or driveway where there may be other traffic.
  • Never use top caps of step ladders as a step.
  • Never place a portable ladder on a box, barrel, pallet, or other unstable base to obtain additional height.
  • Do not move a mobile ladder stand or platform when in use.
  • Equip mobile ladder stands and platforms that have wheels or casters with a system to impede horizontal movement when a worker is on the stand or platform.
  • Provide a ladder safety system or personal fall arrest system on each fixed ladder that extends more than 24 feet above a lower level.

Stairs

  • Do not install spiral, ship, or alternating tread-type unless the employer can demonstrate that it is not feasible to provide standard stairs.
  • Equip flights of stairs having at least 3 treads and at least 4 risers with handrails and stair rail systems.

Dockboards

  • Design, construct, and maintain dockboards to prevent transfer vehicles (e.g., forklifts, power jacks) from running off the dockboard edge.
  • Secure portable dockboards by anchoring them in place or by using equipment or devices that prevent the dockboard from moving out of a safe position. If securing the dockboard is not feasible, ensure there is sufficient contact between the dockboard and the surface to prevent the dockboard from moving out of a safe position.
  • Use measures such as wheel chocks or sand shoes to prevent the transport vehicle (e.g., a truck, semitrailer, trailer, or rail car), on which dockboards are placed, from moving while workers are on the dockboard.
  • Use portable dockboards that are equipped with handholds to permit safe handling of those dockboards.
  • Block exposed or open loading dock doors and other areas where someone could fall.
  • For loading docks, use fall protection on the working side of a platform with and unprotected side or edge that is 4 feet of more above a lower level unless the employer can demonstrate that the use of fall protection systems is not feasible, provided: (1) the work operation for which fall protection is infeasible is in process; (2) access to the platform is limited to authorized workers; and, (3) the authorized workers are trained in accordance with 29 CFR 1910.30.

The following provide additional information regarding fall prevention and walking-working surfaces:

Hazard Communication

Where chemicals are present in a warehouse, and workers may be exposed to those chemicals under normal conditions of use or in a foreseeable emergency, employers are subject to OSHA's Hazard Communication Standard (HCS) (29 CFR 1910.1200). Warehousing establishments are frequently cited under the requirements of this standard.

To implement an effective HCS Program:

  • Become familiar with the provisions of OSHA's Hazard Communication Standard and designate a person with primary responsibility for coordinating implementation.
  • Prepare a written hazard communication program for your facility. (See an example in Appendix A to OSHA's Small Entity Compliance Guide.)
  • Maintain a list of all hazardous chemicals known to be present in the facility and maintain safety data sheets (SDSs) for each. Ensure SDSs are readily accessible to workers.
  • Keep labels on shipped containers and label workplace containers where required.
  • Train workers on the hazardous chemicals in their work area before initial assignment and when new hazards are introduced. Include the requirements for hazards of chemicals, appropriate protective measures, and where and how to find additional information.
  • Review your hazard communication program periodically and when conditions change in the workplace (e.g., new chemicals, new hazards), and revise as appropriate.

In work operations where workers only handle chemicals in sealed containers which are not opened under normal conditions of use, the following applies to these operations only as follows:

  • Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;
  • Maintain copies of any safety data sheets (SDSs) that are received with incoming shipments of the sealed containers of hazardous chemicals, and obtain SDSs as soon as possible for sealed containers of hazardous chemicals received without a safety data sheet if an worker requests it. Ensure that SDSs are readily accessible during each work shift to workers when they are in their work area(s); and,
  • Ensure that workers are provided with information and training (except for the location and availability of the written hazard communication program), to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container. (See )

The following OSHA resources provide additional information about hazard communication:

Process Safety Management

OSHA's Process Safety Management (PSM) standard (29 CFR 1910.119) applies to warehousing facilities that have certain highly hazardous chemicals at or above specific quantities (e.g., ammonia refrigeration systems containing 10,000 or more pounds of anhydrous ammonia - see ), and/or flammables in one site in one location, in a quantity of 10,000 pounds or more.

The PSM standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices. Implementing the required safety programs helps prevent fires, explosions, large chemical spills, toxic gas releases, runaway chemical reactions, and other major incidents. This will ensure that employees, contractors, facility visitors and emergency responders are safe from these hazards. Compliance also benefits employers by minimizing damage to facility equipment and neighboring structures in the event of a release of a highly hazardous chemical. Unexpected releases of toxic, reactive, or flammable liquids and gases in storage facilities with highly hazardous chemicals have been reported for many years.

The following OSHA resources provide additional information about process safety management:

Chemical Warehousing and Distribution

Chemical warehouses and chemical distribution facilities that process, formulate, blend, re-package, store, transport, and market chemical products must manage chemicals safely and securely to prevent workplace injuries and illnesses and catastrophic chemical accidents.

  • Store all chemicals safely and securely.
  • Account for the chemicals in all on-site containers (including aerosol cans, cylinders, storage tanks, etc.) that could be impacted by the same emergency event, such as a fire.
  • Periodically inspect tank systems to ensure their integrity.
  • Ensure adequate secondary containment for chemicals to contain spills or leaks.
  • Ensure hazardous and flammable chemicals are stored in structurally appropriate buildings that are equipped with proper fire protection.
  • Store chemicals away from forklift traffic areas.

Chemical warehouse and distribution facilities must manage hazardous chemicals properly as required by OSHA's Hazard Communication Standard (HCS) (29 CFR 1910.1200), Process Safety Management (PSM) standard (29 CFR 1910.119) and Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120), as applicable. Additionally, chemical warehouse and distribution facilities may be subject to Section 112(r) of the Clean Air Act and the Emergency Planning and Community Right to Know Act (EPCRA) Sections 302, 304, 311, 312 and 313, enforced by the EPA; and the Chemical Facility Anti-Terrorism Standards (CFATS) regulation at 6 CFR 27, and the Maritime Transportation Security Act regulation at 33 CFR 105, enforced by CISA and USCG respectively.

For more information, see the joint EPA/OSHA/CISA Warehouse Safety Advisory.

Emergencies and disasters can strike anywhere and at any time, bringing workplace injuries and illnesses with them. Employers and workers may be required to deal with an emergency when it is least expected and proper planning before an emergency is necessary to respond effectively.

A workplace emergency is a situation that threatens workers, customers, or the public; disrupts or shuts down operations; or causes physical or environmental damage. The Getting Started section of OSHA's Emergency Preparedness and Response Safety and Health Topics Page provides a listing of all of the specific hazards for which the agency currently has information available on its website, as well as links to general emergency preparedness and response guidance.

Warehousing employers should have an emergency plan that describes (1) what is expected of workers in the event of an emergency, including provisions for emergency exit locations and evacuation procedures, (2) procedures for accounting for all workers and visitors, and (3) the location and use of fire extinguishers and other emergency equipment.

Below are emergency planning considerations for warehousing operations.

Exits and Exit Routes (see 29 CFR 1910.37)

  • Keep safeguards designed to protect workers during an emergency (e.g., sprinkler systems, alarm systems, fire doors, exit lighting) in proper working order.
  • Ensure exit signs are illuminated and clearly visible at all times.
  • Keep exit routes and exits free and unobstructed; ensure that exit doors are not locked or blocked.
  • Ensure exit routes are adequately lit.
  • Exit routes must not go through a room that can be locked, e.g., a bathroom, nor may it lead into a dead-end corridor.
  • Mark doorways or passages along an exit route that could be mistaken for an exit with "Not an Exit" or language identifying their actual use, e.g., "closet."
  • If the direction of travel to the nearest exit is not immediately apparent, post signs along the exit access indicating the direction of travel to the nearest exit.

Fire Hazards

If portable fire extinguishers are available and intended for worker use (see 29 CFR 1910.157):

  • Ensure that the fire extinguishers are adequate and appropriate for the hazard present in the facility.
  • Mount, locate and identify fire extinguishers so that they are readily accessible in an emergency.
  • Ensure fire extinguishers are fully charged and operable.
  • Conduct a visual inspection of all fire extinguishers monthly and conduct maintenance annually.
  • Train workers on the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting; retrain workers at least annually.

Medical Services and First Aid (see 29 CFR 1910.151)

  • Ensure a trained first-aid provider is on-site and maintain adequate first-aid supplies. (Note: Employers may instead determine that these services will be provided by a hospital, infirmary, or clinic; however, emergency care for serious injuries must be available within no more than 3-4 minutes of the workplace if there is no employee on the site who is trained to render first aid.)
  • If workers may be exposed to corrosive materials (e.g., in battery charging areas), provide facilities in the work area for quick drenching or flushing of the eyes and body.
  • If employers are responsible for rendering medical assistance as part of their job duties, follow the additional requirements in OSHA's Bloodborne Pathogens standard (29 CFR 1910.1030).

Incidental Chemical Spills*

To prevent spills, ensure chemicals are stored properly in the warehouse (See , above) and:

  • Have a written spill control plan.
  • Train workers how to clean up incidental spills, including how to protect themselves and properly dispose of used materials.
  • Provide proper personal protective equipment and enforce its use.

* Incidental spills are situations where a spilled/released chemical can be absorbed, neutralized, or otherwise controlled at the time of release by workers in the immediate release area, or by maintenance personnel. If there is the potential for a substantial release, then emergency response operations may be subject to the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120).

Other issues may warrant consideration in a warehousing facility's emergency plan, including, but not limited to: bloodborne pathogens; pandemic preparedness; unauthorized access to the facility; and workplace violence, including active shooter situations. Many types of emergencies can be anticipated in the planning process, which can help employers and workers plan for other unpredictable situations.

Note: Warehousing operations subject to certain standards are required to have an emergency action plan that complies with 29 CFR 1910.38. This may include operations that warehouse hazardous substances or that are subject to the provisions of the Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119), (e.g., due to presence of ammonia refrigeration systems), and the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120) due to presence of hazardous substances and the potential for substantial releases.

The following OSHA resources provide more detailed information regarding emergency planning:

Warehouses often contain many different types of electrical equipment and systems, and employers are responsible for ensuring they are free from recognized hazards. OSHA's standards for general industry, including warehousing and distribution, are at 29 CFR 1910.302 through 1910.308 and 1910.331 through 1910.335. Employers should:

  • Install and use listed or labeled equipment in accordance with the instructions included in the listing or labeling.
  • Use factory-assembled cord sets and extension cords that are equipped with a ground wire.
  • Ground all power supply systems, electrical circuits, and electrical equipment and ensure grounding paths are permanent, continuous, and effective.
  • Ensure sufficient clearance in front of electrical panels and around all electrical equipment. Do not use these areas for storage.
  • Guard live parts of electrical equipment at all times.
  • Visually inspect all electrical equipment before use. Remove from service any equipment with frayed cords, missing ground prongs, cracked tool casings, etc.
  • Close unused openings in cabinets, boxes, and fittings.
  • Provide covers for all pull boxes, junction boxes, and fittings

Flexible Cords and Cables:

  • Do not use:
    • As a substitute for fixed wiring.
    • Where attached to building surfaces
    • Through or concealed behind holes in walls, ceilings or floors; or through doorways or windows.
  • Ensure flexible cords and cables are connected to devices and fittings so that strain relief is provided to prevent pull on joints or terminal screws.

Below are some OSHA resources that can assist in protecting workers from electrical hazards.

Workers conducting equipment maintenance or service may be seriously injured or killed if hazardous energy is not properly controlled. Injuries resulting from the failure to control hazardous energy during maintenance activities can be serious or fatal, and may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts, and others.

Warehouse operations need a lockout/tagout program (see 29 CFR 1910.147) to ensure that before any worker performs any servicing or maintenance, the machine or equipment is isolated from the energy source and rendered inoperative. The program must include three core components: energy control procedures, employee training, and periodic inspections.

Workers required to perform these operations should be trained, and all workers should have a working knowledge of the program. Employers should also evaluate the procedures at least annually to ensure they are being followed and that they meet OSHA requirements.

Below are some OSHA resources that can assist in protecting workers from uncontrolled releases of hazardous energy.

Heat illness can affect warehousing workers performing physical work in high ambient heat, especially if the facility is also humid and not climate controlled. Warehousing employers should:

  • Allow new or returning workers to gradually increase workloads and take more frequent breaks as they acclimatize, or build a tolerance for working in the heat.
  • Provide workers with drinking water, rest breaks, and cool, shaded areas.
  • Ensure the warehouse is well-ventilated.
  • Train workers on heat-related illnesses, how to spot common symptoms, and what to do when a worker suspects a heat-related illness is occurring.
  • Monitor workers for signs of illness and ensure access to first aid/prompt medical attention.

The OSHA resources below provide additional information regarding heat illness prevention. (For information about working in cold conditions, see .)

  • Heat. OSHA’s Safety and Health topic page explains what employers can do to keep workers safe and what workers need to know - including factors for heat illness, adapting to working in indoor and outdoor heat, protecting workers, recognizing symptoms, and first aid training
  • Heat Illness Prevention Campaign. Educates employers and workers on the dangers of working in the heat.
  • Inspection Guidance on Heat-Related Hazards. (September 1, 2021). Expands agency’s ongoing outreach by establishing an enforcement initiative to prevent and protect workers from serious heat-related illnesses and deaths while working in hazardous hot indoor or outdoor environments.

In today’s warehouse, there are many new hazards that come from new tools developed to improve efficiency. These new hazards must be addressed by employers to protect worker safety.

There are many automated tools in the warehouse such as conveyors, labelers and automated pallet wrappers. When not properly integrated into the workplace, these tools can create significant struck by, caught between and other hazards.

Additionally, some warehouses may utilize collaborative or non-collaborative industrial robots. Workers should be made aware of the unique hazards associated with working around or with industrial robots.

The following OSHA resources provide additional information:

  • Robotics. OSHA Safety and Health topic page dedicated to preventing the recognized hazards associated with robotics.
  • The OSHA Technical Manual (OTM) has a chapter on robotics that can assist warehouses in keeping workers safe in the presence of both collaborative and non-collaborative robots.

Refrigerated warehousing is the storage of any temperature controlled product to maintain freshness and/or safety. Temperatures are usually less than 50°F, and can be subzero. There are several ways refrigerated warehouses are used. Manufacturers (e.g., meatpackers) may have private cold storage facilities to warehouse products before shipping to customers. End users may have cold storage facilities to store temperature controlled products after they’ve received them (e.g., a large hotel may purchase refrigerated food in bulk and store these items on-site). Most commonly, cold storage is outsourced to a third party logistics provider (3PL), where products stay until they are ready to be shipped to an end user.

Workers working in cold conditions may be at risk of cold stress, including hypothermia and frostbite. In addition, working in cold conditions may exacerbate musculoskeletal disorders (MSDs).

Working in Cold Conditions

  • Train workers on cold stress hazards and prevention.
  • Provide workers with time to become acclimatized to the cold.
  • Provide workers with protective clothing, such as insulated clothes, and insulated and waterproof boots; encourage workers to change out of wet clothes and footwear as needed.
  • Where wet processes are used, and floors may be wet/slippery, maintain good drainage and use grated floors, platforms, or rubber mats to provide a dry place for workers to stand while working.
  • Keep doors to cold storage unlocked or provide an inside release to allow workers to exit. (Per 1910.36(d)(1), workers must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge.)
  • Provide engineering controls such as radiant heaters.
  • Provide workers with regular breaks in warm, dry areas.

For more information:

Ammonia Refrigeration Systems

Many refrigerated warehouses use anhydrous ammonia refrigeration systems. Ammonia spills and releases pose a significant threat to workers from skin contact, inhalation, and fire and explosion. As noted in the section above, ammonia refrigeration systems with 10,000 pounds or more of ammonia are subject to the requirements of the Process Safety Management (PSM) Standard (29 CFR 1910.119); however, many of the requirements of this standard are recommended practices whether or not the ammonia refrigeration system is a covered process.

For more information, see:

Flash Freezing Systems

Some manufacturers or warehouses may utilize flash freezing processes. Generally, these systems use liquid nitrogen in closed loop systems to quickly freeze foods in order to maintain quality. If the system were to develop a leak, nitrogen gas could start displacing the available oxygen in the local workspace. Nitrogen is colorless, odorless gas that cannot be detected without air monitoring technology; therefore, in a short amount of time, ambient oxygen levels could drop dramatically, causing workers to become disoriented, lose consciousness, or even die.

In addition to ensuring proper maintenance of flash freezing systems to ensure their integrity, facilities using these systems should install and maintain oxygen monitoring systems in these areas to alert workers timely of potentially dangerous declines in oxygen levels.

For more information, see:

Workers employed through staffing agencies are generally called temporary or supplied workers. Staffing agencies and host employers (e.g., warehouses) are jointly responsible for maintaining a safe work environment for temporary workers. A key concept is that each employer should consider the hazards it is in a position to prevent and correct, and comply with relevant OSHA standards. For example: staffing agencies might provide general safety and health training, and host employers provide specific training tailored to the particular workplace equipment/hazards.

For more information, see:

Workplace stress and fatigue (e.g., related to a fast-paced working environment and/or the use of continuous performance monitoring systems) can increase worker injury rates and produce negative health effects. Warehousing employers should:

  • Examine and provide workers with opportunities to provide input on staffing issues such as workload, work pace, work hours, understaffing and both scheduled and unscheduled worker absences, which can contribute to stress and fatigue.
  • Arrange schedules to allow for rest breaks and nighttime sleep.
  • Make adjustments to the work environment such as lighting, temperature and physical surroundings to increase alertness.
  • Educate and train workers on the workplace stress and fatigue and their associated health impacts, and the importance of diet, exercise and stress management strategies to minimize the adverse effects.
  • Consider implementing a Fatigue Risk Management Plan.

The following provide additional information: