How to Comply with Foot Protection Requirements

Date First Published on SafetySmart Compliance: February 19th, 2012
Topics: PPE |

OSHA foot protection requirements are contained in Section 1910.136 of the General Industry regulations. Here’s an overview of the requirements and how to comply with them.

OSHA Foot Protection Equipment Requirements

The OSHA Standard requires that all foot protection meet the criteria established at ANSI Z41.1 1999 or by American Standards for Testing and Materials (ASTM) F-2412-2005. This Standard provides design specifications for footwear that provides protection to a worker’s feet from falling and crushing objects, objects that might pierce the sole of the boot and against impact on the sensitive ankle bone.

The Construction Industry Standard for foot protection is found at 1926.96. It simply requires that all foot protection meet the requirements found at ANSI Z41.1 but it references 1967 version. However, as with eye protection and head protection, most foot protection purchased from vendors will meet the most recent ANZI Standard criteria.

Selection of Protective Footwear

Safety footwear must provide appropriate protection to workers’ feet against foot hazards posed by the work, which may include:

  • Heavy or sharp objects such as barrels or tools that might roll onto, fall onto or strike a worker’s feet;
  • Compression injuries when the foot is squeezed between two objects;
  • Sharp objects such as nails or spikes that might pierce the soles or uppers of ordinary shoes;
  • Molten metal that might splash on feet;
  • Hot, wet or slippery surfaces;
  • Electrical hazards such as shock resulting from contact with exposed electrical conductors or grounding;
  • Abrasive or hazardous chemicals that might come in contact with the worker’s foot;
  • Work in areas that are wet or contain puddles of liquids; and
  • Work in areas containing extremely hoto r cold conditions.

Forms of safety footwear include:

Safety Shoes (or Boots): These have impact-resistant toes and heat-resistant soles that protect against hot surfaces common in roofing, paving, and hot metal industries. Some have metal insoles to protect against puncture wounds and some have steel-toes. Other styles may be designed to be electrically conductive for use in explosive atmospheres, or nonconductive to protect from workplace electrical hazards.

Metatarsal Guards: These are used when there is a risk of high impact to the instep or compression and are either an integral part of the shoes or strapped to the outside of shoes.

Rubber Boots: Rubber boots are used to protect a worker’s feet when working in areas where water or other non-hazardous liquids are found. They come in overboots that slip over a worker’s safety shoes or as a separate boot. Some also have steel toes built in and can be worn when traditional safety shoes are needed in wet environments.

Hazardous Materials Boots: Also known as HazMat boots, these are worn when workers feet are exposed to hazardous substances such as acids or solvents. Some types are designed to be worn separately and may also feature a steel-toe or may be an overboot designed to go over a worker’s safety footwear.

Shoe Grips: Shoe grips are used when workers encounter hazards from slippery or icy surfaces. These are often strapped on over a worker’s safety footwear.

Electrical Safety Shoes: There are several variations of these types of footwear, including:

  • Conductive shoes, which prevent static electricity build-up by providing a path to the ground;
  • Static dissipative shoes, which reduce static accumulation while still providing a sufficient level; and
  • Electrical hazard shoes, which provide protection against shock hazards of 600 volts or less under dry conditions.

Sometimes the hazards extend beyond a worker’s feet and up all or part of their legs. In these situations, several additional types of protective footwear are available:

  • Rubber spats: Protect feet and ankles against chemicals;
  • Knee and shin guards: Protect against hazards to the shin and knee;
  • Leggings: Protect the lower leg from molten metal or welding sparks; and
  • Aprons: Protect thighs and upper legs from liquid splashes.

Paying for Safety Footwear

Safety footwear is one of the exceptions related to your responsibility to pay for PPE established by OSHA because footwear is something not easily shared among your workers and because most footwear can be worn by workers outside of the work area. However, if you do not permit your workers to take their safety footwear home at the end of the workshift, you must pay for it.

Because most employers allow workers to select their own safety footwear, it is important that you establish some mechanism for checking to assure that the footwear meets the ANSI Standard. This can be verified by looking at the tag inside the tongue or along the inside of the footwear.

Even though you’re not required to pay for safety footwear, many employers do. They either provide an allowance of a certain amount per year or every other year or they set up a system where they reimburse their workers when they provide a receipt. Some employers also set up visit by Shoe-mobiles; vans that come to the worksite at varying intervals with a supply on shoes and places to try them on. Payment is either made by the employee with a discount set up to be paid by the employer or the employer pays for the total cost.