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Industries

OSHA Compliance for Logistics and Distribution

Peak arrives, agency workers arrive with it, and the forklift traffic doubles. Most of what goes wrong in distribution happens in the twenty feet between a trailer and a dock plate — and most of the people it happens to started this month.

Where OSHA stops and DOT starts

Once a truck leaves your yard, driver qualification, hours of service, vehicle condition and hazmat transport are FMCSA and DOT matters. OSHA governs the dock, the yard and the building: the forklift, the racking, the walking surfaces and the people working around them. Operators routinely assume one agency covers both. It does not, and the obligations do not transfer.

Check the rules in your state

What gets cited

The standards behind the findings that come up most in this work. Each links to the text on osha.gov.

  1. 1

    Powered industrial trucks

    29 CFR 1910.178

    Operators certified once and never re-evaluated. Evaluation is required at least every three years, and retraining is triggered by specific events including a near miss or an unsafe operation.

  2. 2

    Materials handling and storage

    29 CFR 1910.176

    Racking loaded beyond capacity, damaged uprights left in service, and aisles obstructed to the point that a truck and a person cannot pass safely.

  3. 3

    Walking-working surfaces

    29 CFR 1910.22

    Dock edges without protection, standing water, and the housekeeping that separates a busy floor from a dangerous one.

  4. 4

    Fall protection on elevated surfaces

    29 CFR 1910.28

    Work at height on mezzanines, order pickers and dock edges without the protection the general industry rule requires.

  5. 5

    Emergency action plans

    29 CFR 1910.38

    A written plan that names routes, assembly points and the people responsible — per building, not one plan photocopied across the network.

The people who are not on your payroll

Peak runs on agency labour, and the host employer keeps duties toward workers it does not employ. Both employers can be cited for the same condition. The practical question is which of you trained them, which of you assessed the hazard, and whether either of you can show it — which is a records problem before it is a safety problem.

Questions we hear

Who trains agency workers — us or the agency?

Both carry duties. The staffing agency generally handles general safety awareness; the host employer knows the specific hazards of its site and equipment and is expected to train on those. Agree the split in writing and keep the records on both sides.

How often do forklift operators need re-evaluating?

At least once every three years, plus retraining after specific triggers such as an accident, a near miss, an observed unsafe operation, a change of equipment, or a change in workplace conditions.

Does OSHA or DOT cover our drivers?

Driving itself, vehicle condition and hours of service are DOT and FMCSA territory. OSHA covers what happens in the yard, on the dock and inside the building.

Is an injury to a temp worker recordable on our log?

If you supervise the worker on a day-to-day basis, the injury generally belongs on your OSHA 300 log rather than the agency’s. Day-to-day supervision, not who issues the paycheque, is the test.

Do we need a separate emergency action plan for each building?

A plan has to reflect the building it covers — its exits, its assembly points and the people responsible there. One generic document across a network of sites does not do that.

Templates that apply here

Free checklists from the library — no charge, one short form.

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Compliance for logistics, without the consultant

WorkSafely SMB builds the programs above, keeps the training attached to them, and has the records ready when an inspector asks.

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General guidance only, not legal advice. Which standards apply is fact-specific and requirements change. Verify against the current text and consult a qualified professional on your own operation.