It’s imperative to have workers wearing the right shoes for the job.
By Alexandra Walsh
Protective footwear is required for all workers in industrial settings to abide by federal regulations adopted and enforced by the Occupational Safety and Health Administration. Footwear is included in the personal protective equipment section of the OSHA Standard.
What Is the Standard?
The federal government’s standard, 29 CFR 1910.136(a), is clear:
The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.
And at the end of the day, protecting employees’ feet with good industrial footwear is good business—it cuts lost work hours, improves productivity, and heightens morale.
Why Is Regulation Important?
Failure to comply with OSHA regulations invites warnings, sanctions, and fines. Employers can avoid these consequences by simply complying with the regulations through buying employees’ footwear or by providing full or partial reimbursement.
OSHA doesn’t force companies to purchase shoes for workers but encourages those that don’t to require employees to have the right footwear before beginning work.
Consider a comparison of costs. Safety footwear ranges from $80 to $250, which is similar to the cost of an injured employee’s hospital visit. OSHA fines run from a minimum of $2300 to as much as $70,000 per incident.
The Bureau of Labor Statistics, part of the Department of Labor, reports that foot injuries take an average of six days to heal, and around 120,000 workers annually suffer from toe, foot, and ankle injuries. The BLS also cites a study revealing that 75% of these foot injuries occurred when workers were not in compliance.
OSHA suggests protective footwear be worn in situations involving:
- Corrosive or poisonous materials
- Electrical hazards
- Static electricity that could cause an explosion
- Heavy objects that could roll onto feet
- Sharp objects that could puncture the foot
- Molten metal that could splash onto feet
- Hot or slippery surfaces.
Conducting a Hazard Assessment
OSHA recommends employers conduct a risk assessment to determine the need for PPE and the type of footwear employees should wear. Employers should take a broad look at working conditions and procedures and examine a range of possible hazard controls.
OSHA fines run from a minimum of $2300 to as much as $70,000 per incident.
In the hazard-assessment process, safety managers should consider the kinds of operations in a facility or at a jobsite, the processes being used, the tasks being performed, environmental conditions, and the nature of any chemicals in use. They also have to examine key human performance factors such as the fit of footwear or whether the foot will sweat profusely.
Before the selection of any protective equipment, managers need to ask: Why are we protecting this individual? What are we protecting them from? Why are they walking in and around the jobsite?
Preparing walking and working surfaces is a prerequisite to selecting footwear. For example, with a wet surface the employer needs to ask: “Why is there liquid on the floor or ground?” They also need to see if it is possible to eliminate and not accept the wet workplace condition as the norm.
Employers need to consider changes in the work environment when possible. These include new flooring, revamping processes or job tasks, and reassessing what footwear is needed based on those changes.
This hazard assessment should consider simultaneous as well as single hazards. With footwear, you could be walking on a wet surface, but that wet surface can also be chemically contaminated, and you could be working with electrical sources.
OSHA requires employers document that the hazard assessment has taken place. This written certification includes identifying the workplace evaluated, the name of the person who performed the evaluation, and dates of the hazard assessments.
A successful foot protection program starts by documenting a past history of acceptable performance. Other documentation might refer to specific standards or test data for specialized footwear, such as that for electrical safety or chemical protection.
In determining how to eliminate or minimize hazards, safety and health managers should adhere to the traditional hierarchy of engineering controls, administrative procedures, and then personal protective equipment such as footwear.
Selecting the Right Shoe for the Job
Each industry requires safety shoes designed to confront specific dangers. For example,
heat-resistant soles protect feet against hot surfaces in paving, roofing, and hot metal industries. Electrically conductive shoes protect against static electricity to reduce the risk of a spark causing a fire or explosion. Electrical-hazard safety-toe shoes ground the wearer to protect against open circuits up to 600 volts. Foundry shoes have safety toes and are designed to stop hot metal from lodging in shoe parts and eyelets.
OSHA suggests steel-toe shoes for jobs like water well drilling where the danger of heavy objects dropping on workers’ feet is a daily concern.
Shoe manufacturers and retailers can guide workers to the appropriate pair of shoes for their jobs. The more dangerous the position, the more likely the shoe will be created for a narrower range of challenges. For example, firefighters select from product lines created just for them (and regulated by a separate OSHA standard), while electrical-hazard shoes are designed specifically for electricians.
Protective footwear must comply with American National Standards Institute standard ANSI Z41-1991, which breaks footwear down into six categories:
- Impact- and compression-resistance, which uses a steel or nonmetallic toe cap (steel toe) to protect against falling objects or crushing from heavy rolling objects.
- Metatarsal footwear, which provides similar protection against falling objects to the area of the foot between the ankle and the toes.
- Electrical hazard, where the sole of the shoe or boot is designed to protect workers from electric shock from 600 volts or less, under dry conditions.
- Conductive footwear, which prevents the buildup of static electricity.
- Puncture-resistance, where the sole resists penetration from sharp objects, such as nails or broken glass.
- Static-dissipative, which reduces the buildup of static electricity.
Tips for Getting a Good Fit
- Measure both feet. To get the best sizing information, measure from the toe to the heel, the ball of the foot to the heel, then the width. Try both shoes on and walk around in them, if possible.
- Try shoes on in the afternoon. When you’ve been on your feet all day, they swell and expand. If you have sensitive areas on your feet and they hurt when trying on a shoe at that time of day, then you know you need to try a different style.
- Wear a normal work sock. If you wear a thicker or thinner sock at the time of selection, it could result in the choice of shoe that is too small or too big.
- Rotate between old and new shoes. Don’t wait until your shoes are totally worn out before you get a new pair. When you get to three months left of wear and tear, go get another pair and then start rotating them. Both pairs will last longer and be more comfortable.
OSHA provides some additional recommendations. It encourages workers to check safety shoes at regular intervals to determine whether they should be replaced, or at a minimum, cleaned.
Anytime a heavy object hits a steel safety toe, it is likely compromised and should be replaced. Pieces of metal embedded in shoe soles should be removed immediately. Shoes should be cleaned and maintained for best use and increased longevity.
OSHA Resources for Compliance
For employers who want to ensure they comply with applicable regulations, OSHA offers plenty of training opportunities and guidance through grants, strategic partnership programs, voluntary protection programs, and free consultation assistance for small employers. These resources are shown on OSHA’s website home page (www.osha.gov).
From safety toes to slip-resistant heels, businesses have several choices that will help employees avoid foot-related aches, pains, and injuries. Fulfilling OSHA’s mandate is more than just about meeting a governmental obligation. It is about improving the lives of employees and increasing their safety in the workplace.
When employees wear the right OSHA-approved footwear, businesses create healthier and more productive workplaces. Everyone benefits.