Protective footwear

December 3, 2008
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Take a look at OSHA regs governing workplace footwear and you’ll find mention of the types of hazards that necessitate foot and leg protection, types of foot and leg protection available, and the ANSI standards to which this PPE must comply. But don’t expect OSHA to tell you exactly what shoes to wear for the job at hand.

OSHA receives inquiries from various industries asking if a particular type of shoe is acceptable or necessary for their workplace. The answer is not so simple. OSHA policy does not require specific shoes for particular workplaces.

Check out the following Q&A to further clarify OSHA’s stance on safety footwear. (Note: All information is drawn from OSHA Letters of Interpretation, found at www.osha.gov.)

When does OSHA require employees to wear protective footwear?

OSHA regulations pertaining to employee footwear are found at 29 CFR 1910.132 and 1910.136. In general, the standard requires that foot protection be used whenever it is necessary by reason of hazard of processes or environment which could cause foot injury. Normally, the employer will determine which, if any, employees are exposed to a foot injury hazard. This does not mean that those employees requiring foot protection are required to wear foot protection at all times when working. When employees are exposed to the possibility of foot injuries, foot protection shall be worn. When employees are not exposed to possible foot injuries, foot protection is not required by the OSHA standard, and then becomes solely a matter of employment conditions existing between the employer and the employees, and where applicable, subject to any labor/management contractual agreement.

Does OSHA require employees in the electrical trade to wear steel-toe shoes?

No. The employer may require employees to use PPE to comply with the employer’s established safety rules, so long as the PPE itself does not present a hazard. OSHA does not generally consider the wearing of steel-toe shoes by electrical tradesmen to be hazardous, so long as the conductive portion of the shoe is not in contact with the employee’s foot and is not exposed on the outside of the shoe. Consider the purchase of non-metallic safety footwear that provides both foot protection and is non-conductive.

Do OSHA regs permit sandals in a medical office setting where our feet do not contact blood or body fluids?

When there is occupational exposure to blood or other potentially infectious materials (OPIM), the OSHA bloodborne pathogens standard, 29 CFR 1910.1030, requires the employer to provide, at no cost to the employee, appropriate PPE such as, but not limited to, gloves, gowns, eye protection, shoe covers, laboratory coats, or other equipment deemed necessary [See 29 CFR 1910.1030(d)(3)(i)].

Where it is reasonable to anticipate that blood will contact the feet, employers must provide employees with protective gear to cover shoes which will be worn outside. (The bloodborne pathogens standard does not consider shoes worn outside the facility as PPE, regardless of whether the shoes cover the toes or not.) PPE will be considered “appropriate” only if it does not permit blood or OPIM to pass through to or reach the employee’s work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used [See 29 CFR 1910.1030(d)(3)]. Socks are not considered a protective barrier for preventing soak-through of blood or OPIM.

It is the employer’s responsibility to ascertain whether or not there is reasonable likelihood of exposure to blood or OPIM at their workplace. Determination of appropriate footwear in the absence of exposure to blood or OPIM, or any other recognized hazard, would be up to the employer. OSHA does not forbid employers from setting protocol for prescribed work attire.

Would the implementation of a policy requiring employees to wear leather shoes while operating vehicles in the course of their job be a matter of concern to OSHA?

This matter as stated would not concern OSHA because you indicated that the affected drivers would not be in manual handling. The situation described would be a matter of labor-management negotiation. Our conclusion might be different if truck drivers are exposed to hazards to the feet because of tasks performed by the drivers or by other workers. We recommend that you contact the U.S. Department of Transportation to determine if they regulate footwear worn by over-the-road truck drivers.

SIDEBAR: “Pay for PPE” and footwear

Note: In OSHA’s “Pay for PPE” rule issued in November, 2007, the following parts relate to footwear:
  • The regulatory text makes clear that employers are not required to pay for ordinary safety-toe footwear and ordinary prescription safety eyewear, so long as the employer allows the employee to wear these items off the job-site.
  • The final rule clarifies that an employer is not required to pay for shoes with integrated metatarsal protection as long as the employer provides and pays for metatarsal guards that attach to the shoes.
  • The logging standard does not require employers to pay for the logging boots required by 1910.266(d)(1)(v), but leaves the responsibility for payment open to employer and employee negotiation. The final rule makes clear that logging boots will continue to be excepted from the employer payment rule.
In its spring 2008 regulatory agenda, OSHA stated that it is considering amending its standards for general industry, maritime and construction to clarify that when a standard requires the employer to provide PPE to employees, or train employees, each employee not provided PPE or trained is a separate instance of a violation of the standard. The amendment will clarify the remedy available to OSHA for violations of the PPE and training standards; it will not change the standards’ substantive requirements in any way and will add no new regulatory burden.

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