New National Emphasis Program (NEP) will likely increase warehouse oversight for furniture retailers and manufacturers in 2024. Here’s what you need to know.
Interview with Billy Lindler, USSI
Furniture World spoke with Billy Lindler Jr. about what OSHA’s National Emphasis Program (NEP) will mean for furniture retailers. Lindler’s company, USSI (ussipartners.com), provides warehouse storage, equipment and handling consulting, plus existing facility audits, new warehouse design, and operational efficiency assessments.
“In June 2023,” he explained, “OSHA introduced the NEP to address its concerns about warehouse workplace safety and worker environments.
“Anyone who travels to major metro areas knows that the pace of warehouse construction has taken off. It’s part of the Amazon effect, a corporate arms race to place inventory close to customers, shorten delivery times and increase sales.
“This proliferation prompted OSHA to create an NEP, likely to increase warehouse oversight in the furniture business.”
“Sliding 30-plus thousand pounds of merchandise per shift, especially in hot warehouse environments, is a huge amount of physical activity and something that OSHA will look at more closely.”
When asked what types of furniture retailers will be most affected by stepped-up compliance visits, Lindler replied, “Mid-to-large retailers will probably be affected the most. If you’re a retailer serving a small community in South Dakota, it’s less likely that OSHA will come knocking on your door versus being in metro New York, Atlanta or Dallas.”
“To prepare for this interview,” said Lindler, “I asked one of USSI’s higher-volume furniture store customers to share some operations numbers. The average number of pieces one of their order picker operators moves daily is 490. The average customer-calculated weight across their 9,000 SKUs is 65 pounds. That means that one operator moves, on average, 31,850 pounds of material during one shift.
“The reason these calculations matter is the unique nature of furniture warehouses. In most non-furniture warehouses, drivers use sit-down or stand-up forklifts to move pallets. Forklift operators might bend down to pick up cases from a pallet, but their job descriptions don’t include lifting or sliding a 350-pound motion sofa containing electronics and sometimes a separate battery pack. Other massive items moved in furniture warehouses, such as marble slabs and glass tables, are similarly big, bulky, and heavy. The problem is that sliding 300 pounds is difficult or impossible for most people.
“In the automotive world,” Lindler continued, “workers who adapt to the physical demands of specific jobs, like holding a torque tool overhead all day, are called industrial athletes. It’s the same in the furniture industry. Over time, workers get conditioned to do the job. Each sofa, table, and king-size bed in furniture warehouses is manually touched and moved by an order picker operator. Ideally, operators use gravity to position their carts/platforms slightly higher or lower than the shelf to make pushing furniture manually onto or off shelves easier. However, sliding 30-plus thousand pounds of merchandise per shift, especially in hot warehouse environments, is a huge amount of physical activity and something that OSHA will look at more closely.
“OSHA is concerned about ergonomic issues in furniture warehouses, but they also know there aren’t many currently available options to improve the process. Advances in palletizing, goods-to-person systems and robotics may eventually help.”
Palletizing: “Most warehouse assistive devices are designed for handling pallets in operations such as the food and beverage industries. They are called GMA pallets, 40 by 48 inches.
“Some furniture companies have created oversized palletized solutions. Steve Silver Furniture designed custom oversized pallets for a semi-automated, driverless shuttle system to store upholstery. Art Van had a fully Automated Storage and Retrieval System (ASRS) with an oversized pallet. We’ve found that these driverless ASRS system options are cost-prohibitive for retailers—about $1.2 million for the first aisle and perhaps $700,000 for each additional aisle.” Moreover, cube utilization for pallet-based systems is 47% lower, so warehouses using these systems must be larger to accommodate the same amount of inventory.”
Goods-to-Person Systems: “Systems with the most promise to reduce furniture warehouse injuries are called goods-to-person systems. Amazon is famous for creating robots that pick up shelving bins and bring them to pick or replenishment stations. The operator stays in one place. Right now, these Autonomous Mobile Robot (AMR) solutions only work for smaller items.”
Exoskeletons: “OSHA will focus on workplace ergonomics, a growing issue for furniture retailers. So far, we haven’t identified a good solution to the problem of sliding furniture on and off racks. Although USSI has tested active and passive exoskeleton systems, they are primarily designed to help with lower back bending and lifting, not pushing and pulling.”
“One of our clients recently had a temp employee cause over $40,000 in damage to a piece of equipment. Miraculously, that employee wasn’t hurt.”
Heat & Humidity
A link to NEP heat guidelines can be found near the end of this article. OSHA says their “approach is intended to encourage early interventions by employers to prevent illnesses and deaths among workers during high heat conditions. Early interventions include, but are not limited to, implementing water, rest, shade, training, and acclimatization procedures for new or returning employees.”
“To address these heat concerns,” Lindler explained, “retailers might start by measuring warehouse heat and humidity levels, especially on sweltering days. USSI is working with a retailer to install more than 80 temperature and humidity sensors in an 800,000-square-foot warehouse to collect temperature and humidity data at ground level and 15- and 30-foot elevations.
“Once the extent of a heat issue is known, several strategies exist to decrease temperatures. If it’s 95 degrees, bringing the temperature down to 90 or 88 degrees makes a big difference. The question is how to do that in the most cost-efficient way.”
Tempering: “Two years ago, we looked at tempering a large facility by mechanical means. Unfortunately, the size of the initial investment and the utility expenses incurred to decrease the humidity and temperature of such a huge volume of air were cost-prohibitive. The only way to have the math work for a facility like this would be to have significant, concurrent productivity increases. We are currently doing a study to measure the effects of heat and humidity on worker performance and retention.
“Luckily, simpler and more cost-effective cooling strategies can be used.”
Night-time Cooling: “Night-time cooling is especially useful in certain parts of the country where evening temperatures fall below a certain level, say 70 degrees. At that point, a fan system automatically pulls outside air into the facility and exhausts hot air all night. Warehouses have a substantial thermal mass, so dissipating the heat can take some time. When temperatures rise in the morning, the fan shuts off, and the building is sealed. It stays shut all day.
“The cooled-off concrete slab, inventory, racks, etc., help keep the warehouse cooler throughout the day. I’ve noticed that although warehouse employees may want to turn on exhaust fans during the day to get air moving, that makes the environment worse in most cases.”
Humidification: “In arid environments like Utah, Arizona, Nevada, New Mexico and parts of California and Texas, humidifying warehouse air can be an effective and inexpensive way to decrease warehouse temperatures. Many residences use a ‘swamp cooler’ to increase humidity, and similar industrial solutions are available.”
Cooling Rooms, Breaks, Scheduling: “Some of our customers have adapted their break schedules so employees can cool off in air-conditioned spaces or break rooms, hydrate and have access to fresh or convenience foods.”
Clothing and Protective Gear: “We also experimented with cooling vests that use the same technology found in blue ice gel packs. We thought we had a great solution, but the operators hated them, saying they got in the way of their work.”
“If it’s 95 degrees, bringing the temperature down to 90 or 88 degrees makes a big difference. The question is how to do that in the most cost-efficient way.”
Just as most furniture retailers regularly look at metrics such as sales per square foot, they should also track warehouse workers’ sprains, strains and more severe injuries. Lindler observed that “owners who walk around their warehouses at least once a month find that most safety issues become obvious. Keep an eye on the various systems and observe how workers use them. If someone isn’t clipped into their harness, for example, they should be directed to HR and sent home for the day, either with or without pay. This kind of emphasis should be applied to all safety facility issues because OSHA will focus on these kinds of avoidable situations when they visit.”
NEP warehouse safety guidelines state, “The inspections under this NEP, except for high injury rate retail establishments, will be comprehensive safety inspections and will focus on workplace hazards common to those industries, including powered industrial vehicle operations, material handling/storage, walking-working surfaces, means of egress, and fire protection.”
Key Performance Indicators: “Not all retailers,” Lindler added, “measure operations and warehousing KPIs with the same rigor they do on the sales side. I believe that’s a mistake. Accident and injury rates should be tracked to find problem areas that may come up during an OSHA visit.
“If you see something broken,” he continued, “it needs to be fixed. If your worker’s comp rates increase, that’s a red flag. And it’s a good idea to benchmark your operation against similar furniture retailers.
“I wanted to do this interview,” he noted, “because, beyond the top 100, very few store owners or managers know about the safety aspects of the new NEP regulations.
“Safety includes big issues like rack and picker maintenance and seemingly small things like requiring warehouse workers to wear composite safety-toe shoes. Retailers who attended a recent USSI client meeting were asked if they required these shoes. Some did, and some didn’t. Then, a few days after the meeting concluded, one participant told me that a picker drove over an associate’s foot. Remember, it’s not enough to have a footwear rule. Policies must be put in place to make it effective. Will they buy their shoes, or will they be reimbursed? What happens if ‘Billy’ shows up wearing tennis shoes? Do you send him home to get them? Every policy has to be thought through.”
Equipment Maintenance: “Perform machine checks at least once a week. It’s essential to have a formal equipment maintenance schedule and keep service logs to prove that warehouse equipment is adequately maintained, operational and safe. Lift providers like Crown, Raymond, Yale and others are good at providing these services.
“Replace equipment when it’s past its useful life. I visited a potential customer a couple of years ago who was using an old order picker without working brakes. At the end of each rack aisle, they fashioned big, clear plastic bumpers made of packaging waste to stop it. That’s no way to run a warehouse.
“If OSHA does come knocking, show that you have good internal processes in place and are taking steps to monitor and ensure worker safety. Consider putting up safety signage because optics matter.”
“Safety includes big issues like rack and picker maintenance and seemingly small things like requiring warehouse workers to wear composite safety-toe shoes.”
Prep and Deluxing: “These areas have aerosol spray cans for touch-up that are flammable and emit VOCs.
“OSHA will want to know that the cans are stored in a fireproof cabinet at the end of the day when, in most locations, no one is in the warehouse. In a fire, aerosol cans blow up and become projectiles. Don’t be surprised if OSHA asks to audit spray can purchases to estimate the volume of VOCs emitted into a facility.”
Batteries: “If your equipment uses lead-acid (instead of lithium ion) batteries that off-gas in charging areas, it’s required to have eye wash stations and adequate ventilation.”
Miscellaneous Issues: “The dock is another area OSHA will focus on. Small retailers that don’t have a dock-height door may attract attention. OSHA will also notice basic things like portable fire extinguishers that are not fully charged or expired.”
Temp Workers: “A final consideration from a safety and compliance standpoint is the seasonal nature of many furniture businesses. It’s important to be strategic about where you employ temp labor. For example, assigning a temp operator to run a compactor or other heavy equipment is probably a mistake. Consider the task and the risk. One of our clients recently had a temp employee cause over $40,000 in damage to a piece of equipment. Miraculously, that employee wasn’t hurt.”
Turnover & Performance
Lindler said retailers should also look at the broader impact of uncomfortable or potentially dangerous warehouse conditions from perspectives beyond OSHA compliance. “OSHA isn’t concerned about your retail staffing problems,” he noted, “but the warehouse safety issues they are concerned about also affect employee turnover and worker performance.
“Let’s say,” he surmised, “a recruiter contacts an order picker operator who works in a Florida or South Texas furniture warehouse, offering a job at a large national grocery chain. That operator has an opportunity to work in a refrigerated warehouse, sit down all day on a forklift machine and make 50 cents more an hour. It’s not much of a decision for a guy who just moved 31,000 pounds of furniture in a sweltering furniture warehouse that day.”
Furniture World asked Lindler if the vast amount of information on osha.com can be daunting. “At the very least,” he replied, retailers should download OSHA’s pocket guide, a simplified checklist.”
- OSHA Pocket Checklist https://www.osha.gov/sites/default/files/publications/3220_Warehouse.pdf
- National Emphasis Program on Warehousing and Distribution Center Operations https://www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-026.pdf
- Prevention Heat Hazard Recognition https://www.osha.gov/heat-exposure/hazards
Some of this code stuff,” he continued, “is subject to interpretation, and it may not be clear whether or not it applies, for example, regarding indoor air quality (https://www.osha.gov/laws-regs/standardinterpretations/2003-02-24). There are a mix of regulations and recommendations.
“Beyond a do-it-yourself approach, some third-party audit companies conduct safety audits. We also do audits, primarily for rack storage systems and dock and lift equipment.
“I don’t want to represent USSI as an OSHA expert; however, we are closely following how the new NEP regulations will impact furniture retailers,” Lindler concluded. “We must all pay attention and see where OSHA’s new emphasis takes us.”
Russell Bienenstock is Editor-in-Chief of Furniture World Magazine, founded 1870. Comments can be directed to him at email@example.com.