When I was a young boy my mother would tell me about the time her foot was run over by a lift truck. She was working in a steel mill operating controls that would require her to stand in one area. A lift truck swung into her workstation and ran over her foot, crushing her big toe. It's too bad this happened before steel-toe shoes were required in the steel industry, because they would have prevented this injury.

Protecting employees' feet is just one factor in a comprehensive personal protective equipment (PPE) program, but it is an important element. Similar to any piece of PPE, a risk assessment must be performed to identify the hazards in a particular task or area. Identifying when and where foot protection is needed is as simple as reviewing the task, looking at the foot hazards involved and identifying the correct footwear.

Assessing the job

Involve your employees in the hazard assessments. It is important to get their support as you move forward with the protective footwear program. When the hazard assessment is complete you will be able to identify the correct protective footwear:

1) At a minimum, sturdy work shoes are required for all work activities where foot protection is deemed necessary. This means open-toe shoes and sandals would not be allowed.

2) The next level would be steel-toe shoes. These feature a steel cap over the toe area.

3) The third level would be metatarsal shoes, which have steel covering from the toes up over the instep.

Other protection that may be necessary:

  • When working around chemicals, chemical-resistant boots should be worn.
  • Puncture protected soles will be designated with a "PR" for puncture-resistant.
  • Electrical rated shoes for maintenance personnel will be designated with an "EH" for electrical hazard.

Written program

The Occupational Foot Protection Standard, 29 CFR 1910.136 covers the regulation on safety shoes and should be reviewed before writing the protective footwear procedure for your company. Safety shoes, according to OSHA, must meet compression and impact standards. Look for "ANSI Z41.1" markings on the shoe.

The safety shoe program will need to be in the form of a written procedure that explains the purpose of the program along with the specific rules. Be sure to identify the specific areas where protective shoes will be required and the type of shoes needed.

For example: "Metatarsal type safety shoes will be required for all personnel entering the extrusion area."

Who pays?

How shoes will be purchased and who pays for them must be clearly established in your plan before it is rolled out.

The employer is not automatically required to provide PPE of a personal nature such as work gloves or uniforms if the PPE would normally be worn outside of the workplace as well as in the workplace. For instance, a pair of steel-toe safety shoes can be worn off the job as well as at work, so the employer can require the employee to purchase the shoes with their own funds. On the other hand, if the safety shoe is a chemical-resistant rubber boot not normally worn away from the job, the employer would supply it.

Many times the employer pays for all or part of the cost, but be careful when identifying how much the company contributes. I have seen companies that supply two pairs of safety shoes, of the employee's choice, per year. With steel-toe shoes costing up to $200 per pair, you can imagine the cost involved.

After identifying the amount the company will supply towards the shoes it is time to identify a safety shoe supplier. Talk with a number of suppliers and then designate one or more that will come to your site with a shoe truck on a regular basis. If your company is reimbursing part of the cost of shoes you can designate which shoes may be purchased from the supplier. Identify four or five styles that will be eligible for the company contribution towards the purchase. This gives you control of the type of shoes that can be worn, and also makes it very apparent when someone isn't wearing their steel-toe shoes.

Let's roll

After performing the risk assessments and identifying the correct protective shoes, you will be ready to roll the program out to the workforce. You can communicate the program in several ways. If you involved the employees in the hazard assessments, the workforce will already be aware that some workers may be required to wear protective footwear. Meet with all personnel to let them know why the new program is being put in place. Share the findings of the hazard assessments, and show the workers the shoes that will be available for purchase and the procedures for buying them.

A well-planned safety shoe program will reduce injuries and can be easily managed. Just be sure and have your plan ready before rollout.