Determining if Foot Protection is Necessary or Required
The initial step for assessing the need of personal protective equipment (PPE) is a hazard assessment. The assessment is an important element of a PPE program because it produces the information needed to select the appropriate PPE for any hazards present or likely to be present at particular workplaces.
For example, protective footwear must be worn when there is the hazard of:
Falling or rolling objects
- Stubbing or banging
- Chemical or corrosive contact
- Electrical shock
- Slips and falls
What's Involved in Performing a Hazard Assessment?
Since this is a performance-oriented standard, employers must act in a reasonably prudent manner in determining when and how employees, who are exposed to foot injury hazards, are to be protected. In one recent decision, a Federal Appellate Court held that one employer who required its employees to wear sturdy work shoes and made steel-toed footwear available to these employees at a discount, was acting reasonably. A policy requiring steel-toed shoes was found not necessary despite the presence of some foot hazards. OSHA believes that what is reasonably prudent with regard to foot protection may depend on:
- the frequency of the employees' exposure to foot injury,
- the employer's accident experience,
- the severity of any potential injury that could occur, and
- the customary practice in the industry.
Determining Type of Footwear
Select protective footwear based on the hazard assessment. For example:
- Steel-toed shoes to resist impact
- Metatarsal guards to resist impact above the toes
- Reinforced flexible metal soles or inner shoes to protect against punctures (assuming there's no risk of electrical contact)
- Sandals and open-toed shoes are prohibited in laboratories (including art studios), and food service areas (for safety and hygienic reasons)
- For falling objects, use footwear with steel toes.
- Use metatarsal guards if there is the hazard to the metatarsal region above the toes.
- Wear chemical resistant footwear (e.g., rubber, neoprene) in areas with potential chemical or corrosive splashes. Check the MSDS to match footwear with individual chemicals.
- Replace worn footwear.
Even if protective footwear is not deemed necessary, employees should still wear sturdy shoes with nonskid soles. Sandals, sneakers or dress shoes may not be appropriate for many physical activities.
Frequently Asked Questions Regarding Protective Footwear:
- Is there a specific OSHA law in regard to foot protection?
Actually several OSHA standards establish rules and guidance. OSHA's Occupational Foot Protection Standard, 29 CFR 1910.136, requires that employees wear protective footwear when exposed to dangers from falling objects, objects piercing the sole, or electrical hazards. The OSHA Personal Protective Equipment (PPE) Standard also requires that supervisors conduct a hazard assessment, develop a written plan, enforce policies, and train employees in foot protection concepts.
- What are the performance standards for protective footwear?
As a minimum standard of protection, all safety footwear must meet the general requirements for impact and compression resistance, as required by ASTM F2413 (or ANSI Z41, Class 75, for footwear purchased prior to March 2005).
- What if an employee shows up at work and has forgotten his/her protective footwear?
The employer is not obligated to provide employment if the employee fails to act in a reasonable and safe manner. So, if the employee is not prepared for work (i.e., lacking proper footwear), they do not need to be given work. In fact, assigning a task which requires foot protection when a worker doesn't have the right shoes would be considered negligent.
- I've been told by my supervisor I must wear protective footwear because of my job. Can I be disciplined for not wearing it?
- Is the wearing of foot protection the employer's or employee's responsibility?
Technically, the burden is the employer's responsibility. For example, the employer is responsible for conducting the hazard assessment, the selection of PPE, determining the limitations of PPE, training, and ensuring the employee does what is required (i.e., enforcement). However, the employee must also assume responsibility to act in safe and healthful manner.
- Is employee training required for occupational foot protection?
Yes. Once it has been determined that PPE is required, employees must be trained in the proper use and limitations of the equipment. For example:
- When PPE is necessary
- What PPE to use for particular hazards
- Limitations of PPE
- How to put on, adjust, wear, and remove PPE properly
- Care and maintenance of PPE.
Training needs to be sufficient to cover these five points. This can be covered in New Employee Orientation, or during on-the-job training.
- Who pays for the foot protection?
The employer is not required to provide PPE of a personal nature (e.g., uniforms, work gloves, footwear, etc.), for the employee. However, the employer is required to ensure that protective footwear is worn if the hazard assessment determined that such PPE is necessary. The employer may specify the type of PPE to be worn or, for that matter, prohibit what should not be worn (e.g., no bare feet, sandals, open toed shoes).
Some employees receive shoe reimbursement as part of collective bargaining.
The employer (UWM) does need to provide specialized PPE, such as welding helmets and chaps, respirators, hearing protection, etc. The test is whether the PPE would normally be worn outside of the workplace as well as in the workplace. If yes, the worker may be required to buy, or the employer may supply. If no, the employer must supply the necessary PPE.
- "Is foot protection (e.g., steel-toed shoes) required for employees working, for example, on loading docks?"
There isn't a simple "yes" or "no" response. A reasonable answer would probably be: "It depends on the circumstances and the likely hazards."
- I've heard that steel-toed shoes may actually increase the extent of injury should a heavy object crush the shoe. Is this correct?
Steel-toed shoes are very effective in preventing injury to the toes as is so common in the workplace. All PPE, including protective footwear, has limitations. Severe injury hazards as you described should be eliminated using engineering controls, not by the mere use of PPE.
- Have we had any foot injuries at UWM due to lack of protective footwear?
Yes. In one instance, a research assistant had two toes amputated when an I-beam fell from its support. The beam was only one foot off of the floor. Protective footwear would have prevented this injury. Regardless, this hazard should have been identified and eliminated by "engineering" a better support for the beam.
- What kind of shoe should electricians wear?
Shoes with non-conductive soles meeting the requirements of ANSI Z41 PT9l (M/F) I-75 C-75 EH. "EH" represents the "electrical hazard" designation.
- What kind of shoe protects against punctures?
At a minimum, a sturdy work shoe must be worn where injury from puncture is likely. Boots with steel insole: ANSI Z41 P91 (M/F) I-75 C-75 PR "PR" is the "puncture resistant" designation.
- What kind of shoe should be worn to prevent static buildup?
ANSI Z41 P91 (M/F) I-75, C-75 SD Type I. "SD" is the "static discharge" designation.