- ISHN GLOBAL
- EHS RESEARCH
All good safety programs start with a strong foundation, so when determining your employees’ personal protective equipment (PPE) needs, why not start from the ground up. Here’s a short primer on the ABC’s of workplace foot protection.
Assess the hazards The first step in a protective footwear program is to determine whether the hazards encountered in your workplace warrant the use of safety footwear.
In its regulation 1910.136 (a), OSHA states, “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, and where such employee’s feet are exposed to electrical hazards.”
In order to determine if these hazards are present in the workplace, OSHA requires employers to conduct a hazard assessment. OSHA 1910.132 (d)(1) states: “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).” Once the need for PPE has been established, employers are required to select PPE that will adequately protect employees from the hazards identified in the assessment.
Buy the footwear
While it is the employer’s responsibility to ensure that employees wear protective footwear when exposed to certain on-the-job hazards, it is not necessarily the employer’s responsibility to purchase the footwear for the employee. According to an OSHA rule issued in November 2007, employers are not required to pay for the following footwear:
- Ordinary safety-toe protective footwear as long as the employer allows the employee to wear the footwear off the job site;
- Shoes with integrated metatarsal protection as long as the employer provides and pays for metatarsal guards that attach to the shoes;
- Logging boots required by 1910.266 (d)(1)(v).
When purchasing footwear, remember to evaluate all options to choose the best shoe or boot for your workplace. Available options include: steel or composite safety toes, electrical hazard rating, puncture resistance, static-dissipative properties, chemical resistance, slip resistance and moisture control.
You should also evaluate the different options for footwear purchase â€” including mail order, shoemobiles and retail stores â€” to determine which best suits your needs.
Continue to monitor your PPE program
An employer’s responsibility does not end once proper footwear has been selected and purchased. In 1910.132 (f), OSHA requires that employers train workers on when PPE is necessary; what PPE is necessary; how to properly don, doff, adjust, and wear PPE; the limitations of the PPE; and the proper care, maintenance, useful life and disposal of the PPE.
Employers need to ensure that workers continue to wear the appropriate protective footwear when required and that they are wearing it properly. Experts say it is also important to regularly check the condition of PPE for wear and tear. Safety footwear must be promptly replaced if it has become so old, worn or damaged that it will no longer provide adequate protection.