Warehouse Safety Program: Top Hazards, OSHA Requirements, and What Kills People in Warehouses

Warehouses don’t make the news the way construction sites do. No dramatic falls from steel, no cave-ins. But the injury numbers tell a different story.

The Bureau of Labor Statistics consistently shows that warehousing and storage workers suffer injuries at rates well above the all-industry average. The NAICS 493 (warehousing and storage) sector logged a total recordable incident rate of around 5.0 per 100 full-time workers in recent BLS survey years, compared to roughly 2.7 across all private industry. That gap doesn’t close on its own.

The growth of e-commerce has made this worse. Fulfillment operations run faster, with higher throughput and more workers per square foot than traditional storage warehouses. That combination drives both ergonomic and collision-type injuries up. The injury rate conversation in the industry has intensified in recent years as large operators have faced public scrutiny over their recordkeeping and incident reporting practices.

A real warehouse safety program doesn’t happen by accident. It’s built deliberately, and it targets the specific hazards that actually injure warehouse workers.

The Five Hazard Categories That Drive Warehouse Injuries

Forklifts and Pedestrian Traffic

This is the one that kills people. OSHA data consistently shows forklift-related fatalities in general industry, and warehouses are where many of them happen. The most common scenarios are pedestrian workers struck by forklifts in travel lanes, tip-overs when forklifts are loaded unevenly or driven too fast on dock plates, and workers pinned between forklifts and fixed structures.

The core problem is that most warehouses mix pedestrian and forklift traffic in the same spaces. Picking aisles, staging areas, and the area near the loading dock are all high-mix zones. Yellow painted lanes and floor markings help, but they don’t stop a forklift driver who can’t see around a load. Physical barriers, segregated pedestrian paths, and strict speed limits in mixed-traffic areas are what actually reduce risk.

Your forklift safety program needs to address pedestrian segregation as a primary control, not an afterthought.

Racking Systems and Falling Objects

Warehouse racking is not indestructible. Forklift impacts, overloaded bays, and missing safety clips create unstable storage that can fail without warning. When a racking bay collapses, it can trigger a progressive collapse of the entire row. Workers get buried.

OSHA doesn’t have a specific racking standard. What applies instead is the General Duty Clause, Section 5(a)(1) of the OSH Act, which requires employers to provide a workplace free from recognized hazards. OSHA inspectors use the RMI (Rack Manufacturers Institute) ANSI MH16.1 standard as the benchmark for what “safe racking” looks like.

Inspection frequency matters. Any racking damage, from bent uprights to missing column protectors to shim stacks under feet, should be tagged out of service the same day it’s found. Don’t wait for a scheduled audit. Post load capacity placards in every bay and make sure supervisors know what to do when a placard is missing or unreadable.

Striking materials are another part of this hazard. Upper storage levels sometimes hold items that aren’t secured against vibration or impact from forklift operations. Falling objects injure workers below, often without any warning.

Loading Docks and Fall Hazards

The loading dock is the most hazardous square footage in most warehouses. Multiple hazard types converge in a small area: moving vehicles, open drop-offs, pedestrian and forklift traffic, and poor lighting in some older facilities.

The fall hazard at dock doors gets underestimated. Under 29 CFR 1910.28, employers must protect workers from falls of 4 feet or more in general industry. An open dock door without a trailer docked to it is a 4-plus-foot drop onto a hard surface. When that door is open and workers are nearby, fall protection applies.

Vehicle restraints or wheel chocks before anyone enters a trailer, every time, is not optional. Trailer creep, where an unrestrained trailer rolls forward during loading, is a real and recurring event. Workers inside or on dock plates die from it.

Beyond falls, the dock is where forklift-pedestrian conflicts are most acute. Truck drivers moving between their cab and the trailer, warehouse workers on dock plates, and forklifts moving in and out of trailers all occupy the same 20 feet. Clear communication protocols between dock workers and drivers need to be explicit and enforced.

Your fall protection program should specifically address dock door fall hazards, not just elevated work platforms.

Ergonomics and Overexertion

By volume, overexertion is the largest single injury category in warehousing. Manual material handling in picking, packing, and replenishment operations generates musculoskeletal injuries at rates that can wreck a workforce over time. Lower back injuries, shoulder strains, and wrist disorders from repetitive tasks accumulate gradually and show up in OSHA 300 logs and workers’ comp costs.

OSHA doesn’t have a specific ergonomics standard in general industry (the proposed standard was withdrawn in 2001 and hasn’t been replaced). But the General Duty Clause still applies to ergonomic hazards where the employer knows they exist. And the indirect costs of ergonomic injuries, through workers’ comp, reduced productivity, and turnover, are substantial.

Practical controls include job rotation to limit time on high-repetition tasks, mechanical assists for heavy lifts, workstation height adjustments for packing lines, and training workers to recognize early symptoms of musculoskeletal strain before they become recordable injuries.

Electrical Hazards and Equipment Maintenance

Battery charging stations for electric forklifts and equipment create hydrogen gas during charging. That’s a real explosion risk in enclosed areas. Proper ventilation in charging rooms, no ignition sources, and eyewash stations for battery acid exposure are requirements, not suggestions.

Your lockout/tagout program applies to any warehouse maintenance work on powered equipment. Conveyor systems, automated sortation equipment, and dock levelers all have stored energy that requires LOTO before anyone works on them.

OSHA Standards That Apply to Warehouses

OSHA doesn’t have a single warehouse standard. These are the regulations most commonly cited in warehouse inspections:

29 CFR 1910.178 covers powered industrial trucks. This is the forklift standard and it generates more warehouse citations than any other single rule. Training, daily inspections, and operational requirements are all in here.

29 CFR 1910.147 is lockout/tagout. Any maintenance on warehouse conveyor systems, dock levelers, or other powered equipment triggers LOTO requirements.

29 CFR 1910.22-23 covers walking and working surfaces, including floor condition, aisle marking, and fixed ladder requirements.

29 CFR 1910.303-308 covers electrical wiring and equipment. Battery charging areas fall under this.

29 CFR 1910.36-37 covers exit routes. Warehouses with large footprints sometimes have inadequate or obstructed exit paths.

The General Duty Clause covers the gaps. Racking hazards, ergonomic hazards, and some dock safety hazards get cited here when no specific standard directly applies.

What Your Warehouse Safety Program Must Include

A written safety program for a warehouse isn’t optional if you have more than a handful of employees and any of the above hazards present. Here’s what it needs to cover.

Hazard identification comes first. That means a formal job hazard analysis for your highest-risk tasks: forklift operation in pedestrian areas, manual material handling on heavy pick lines, work in or around dock doors, and any maintenance tasks on powered equipment.

Written programs are required for specific hazards. You need a written LOTO program under 1910.147. You need a written powered industrial truck program covering training, evaluation, and retraining under 1910.178. If you have hazardous chemicals (including battery acid), you need a hazard communication program under 1910.1200.

Your emergency action plan is required under 29 CFR 1910.38 if you have 10 or more employees. It needs to cover fire evacuation, tornado procedures if you’re in a relevant region, and any site-specific emergency scenarios.

PPE assessment is required under 29 CFR 1910.132. You need a documented assessment showing what PPE is required for which tasks. Steel-toed footwear, hi-vis vests in forklift traffic areas, and eye protection in battery charging areas are common requirements in warehouse settings. Your PPE program should be built off that assessment.

Training requirements are specific to each standard. Forklift operators need initial training and evaluation, plus retraining after accidents or observed unsafe operation. LOTO requires training for both authorized (people who perform LOTO) and affected employees (people who work near locked-out equipment).

Inspection and recordkeeping close the loop. Daily forklift inspections under 1910.178(q), regular racking inspections, dock equipment inspections, and documented training records all need to exist and be retrievable during an OSHA inspection.

One recordkeeping issue that catches warehouse employers during inspections: training records for employees who have since left the company. OSHA inspectors can ask for records going back years. If your training records live in a supervisor’s notebook that got thrown out, you can’t demonstrate compliance. Keep records in a central, durable system, even a shared spreadsheet is better than nothing.

One Place to Start

If you’re building a warehouse safety program from scratch and you can only focus on one thing first, focus on forklift-pedestrian separation. Physical separation, meaning painted lanes enforced with barriers, combined with right-of-way rules and speed limit enforcement, prevents the type of fatalities that generate OSHA fatality investigations and criminal referrals.

Every other hazard in a warehouse is serious. But the forklift-pedestrian conflict is the one most likely to kill somebody in the next 12 months.