Food Safety
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The Occupational Safety and Health Administration’s (OSHA) National Emphasis Programs (NEPs) are temporary programs that focus OSHA’s resources on particular hazards and/or high-hazard industries. OSHA identifies these programs by evaluating inspection data, injury and illness data, National Institute for Occupational Safety and Health (NIOSH) reports, peer-reviewed literature, inspection findings, and other available information sources.
Federal NEPs
OSHA currently has twelve active federal NEPs. In 2026, OSHA’s priorities concentrate on industries with high injury rates, severe hazards, or historically high non‑compliance. The table below highlights three NEPs that are on the top of OSHA’s list for 2026 and the most impacted industries under each.
| NEP | Description | Most Impacted Industries |
| Heat-Related Hazards | This NEP covering both indoor and outdoor heat hazards has been extended through April 8, 2026. OSHA inspectors are already evaluating heat risks and mitigation efforts (i.e., water, rest, shade, training) during site visits under existing OSHA regulations and will continue to target sites where the heat index is > 80°F. | Agriculture, construction, warehousing, manufacturing, outdoor labor. |
| Warehousing and Distribution Centers | This three-year program, which runs through mid-2026, targets high-injury rate facilities, focusing on powered industrial vehicles, material handling, walking-working surfaces, and fire protection. | Warehouses, distribution centers, logistics hubs. |
| Amputations in Manufacturing | Renewed in 2025, this program continues to focus on machine guarding and lockout/tagout (LOTO) procedures. | Iron foundries, plastics, metalworking, food manufacturing, machine‑intensive industries. |
Regional and Local Emphasis Programs (REPs/LEPs): Focus on Food Manufacturing
Much like federal NEPs, REPs and LEPs are established at the regional or local (area office) level to target hazards or industries with specific risks to workers in that area. Essentially, while REPs have a broad application across a region, LEPs focus on addressing localized hazards or industry-specific risks. Although distinct from NEPs, REPs and LEPs influence OSHA inspection priorities.
While REPs/LEPs can focus on any industry, there are currently many that target food manufacturing, primarily related to high injury/amputation rates, machine guarding failures, LOTO/hazardous energy control issues, and cleaning/sanitation hazards. Generally speaking, these REPs/LEPs involve increased inspections, outreach, and enforcement to address risks to permanent and temporary workers, particularly in the following targeted industries:
- Animal slaughtering and processing (NAICS 311611).
- Animal food manufacturing (NAICS 311111).
- Additional food processing operations, including cleaning and sanitation operations.
Preparing for NEPs/REPs/LEPs and OSHA Inspections
Companies in targeted industries (as outlined above) need to be aware of OSHA’s heightened focus areas for 2026, prepare for potential OSHA inspections, and build a solid foundation for compliance:
- Strengthen Heat Illness Prevention Programs. Conduct heat surveys in indoor and outdoor areas to evaluate and understand heat-related concerns. Update and implement a Heat Illness Prevention Plan (HIPP) before peak summer months when the heat index is likely to climb > 80°F. Develop and implement practices to ensure workers have adequate water, rest, and shade, and verify and document training and monitoring processes.
- Improve Machine Guarding and LOTO Programs. Conduct detailed reviews of machine guarding, including point‑of‑operation and interlocks, to ensure it meets requirements and adequately protects staff. Audit LOTO procedures to ensure they are compliant, documented, enforced, and understood. Regularly train all machinery operators on machine guarding and LOTO.
- Conduct Internal Warehouse & Distribution Center Audits. Internal audits of warehouses, loading docks, and storage areas can help facilities identify problems—particularly related to OSHA’s focus areas—and implement corrective actions before an OSHA inspection occurs.
- Address REP/LEP Risks. Many regions—including Wisconsin, Illinois, and Ohio—have strong LEP/REP activity around food manufacturing, machine guarding, sanitation hazards, and LOTO. Food manufacturers should conduct regular internal audits of sanitation practices, machine guarding equipment, and energy control procedures. Importantly, employees must receive adequate training on both how to safely operate equipment in the food manufacturing environment and hazards related to the chemicals used for cleaning and sanitation purposes.
- Anticipate More Unannounced Inspections. A second-party mock OSHA inspection is one of the best ways to identify hazards, areas of concern, and opportunities for improvement in operational practices and documentation requirements. A second-party auditor can provide an objective assessment of overall compliance status, so non-conformances don’t catch you off guard.
- Reinforce Worker Training and Communication. Training is a consistent requirement across all NEPs/REPs/LEPs to meet compliance requirements and, more importantly, to ensure all employees have a clear understanding of safety procedures and expectations.
