Sometimes a Shoe is Just a Shoe? Not in the Workplace

Good programs really can produce happier, more productive employees.

• By Benjamin W. Mangan
• Oct 01, 2006

SIGMUND Freud, the father of psychoanalysis and one of the most authoritative thinkers of all time, is often quoted as having said, "Sometimes a cigar is just a cigar." By that he meant, sometimes a person just wants to smoke a good cigar, so people shouldn't try to read any special significance into it. It's not something a person should overthink.

Freud's logic, however, doesn't work so well in the workplace.

Take, for example, protective footwear. Sometimes a shoe is just a shoe . . . . Is that true? Don't bet on it. Any company that assumes all protective footwear is the same would be doing its workers a serious disservice, opening the door to potential injuries. Many important factors need to be considered when selecting the right protection for workers' feet.

How do you, as an employer, know what kind of protective footwear to buy? Let's look into what the OSHA has to say on the matter, because compliance with OSHA standards is a high priority for the business community. OSHA standards provide guidelines for the selection of all personal protective equipment, which includes protective footwear.

What OSHA Has to Say
According to OSHA's 29 CFR, Part 1910, General Industry regulations, Subpart I, Personal Protective Equipment, 1910.132 General Requirements, you must assess the workplace to determine whether hazards are present, or are likely to be present, that make the use of PPE necessary. Such an assessment is necessary to determine which hazards must be addressed. In the case of protective footwear, the nature of those hazards will help in selecting a product with the right protective properties.

Our company's "Essentials of Safety" class includes a concept we call Safety ESP™. Those three initials can help you to determine how to address workplace hazards:

• Engineering controls
• Safe work practices
• Protective equipment

If there is a reasonable chance that something could hurt your employees' feet, then first you must try to engineer out the hazard, determine safe work practices to minimize it, and finally select the proper protective equipment to keep your workers as safe as possible.

If the assessment determines that hazards are either present or likely to be present, you must select, and have affected employees use, the types of PPE that will protect that employee from those hazards. If the equipment is employee-owned, you're still responsible for ensuring its adequacy, including proper maintenance and sanitation of that equipment. You must make sure defective or damaged PPE cannot be used.

In 1910.136, OSHA identifies some of the hazards that need to be addressed when selecting protective footwear: "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."

A partial list of occupations for which foot protection should be considered would include assemblers, carpenters, drywall installers and lathe operators, electricians, freight handlers, gardeners and groundskeepers, laborers, machinists, mechanics and repairers, packers, plumbers and pipefitters, punch and stamping press operators, sawyers, shipping and receiving clerks, stock clerks, structural metal workers, timber cutting and logging workers, warehouse laborers, and welders.

What's the Deal with ASTM?
When checking out the specifications for protective footwear, you may notice that many new shoe labels refer to the American Society for Testing and Materials (ASTM). This may lead you to wonder, are those shoes still compliant with OSHA regulations?

The answer is yes: According to OSHA standard 1910.136(b)(1), protective footwear purchased after July 5, 1994 must comply with American National Standards Institute (ANSI) standard Z41-1991, "American National Standard for Personal Protection--Protective Footwear," or shall be demonstrated by the employer to be equally effective.

As you will see later, footwear that meets ASTM standard F2413-05 meets and exceeds the ANSI Z41 standards, and so it meets OSHA standards and is compliant.

What Hazards Does Protective Footwear Guard Against?
The ASTM F2413-05 standard divides safety shoes into two categories: impact resistance and compression resistance. Impact and compression requirements gauge the shoe's ability to protect the wearer from falling or rolling objects. Impact- and compression-resistant shoes are made using a steel or nonmetallic toe-cap for foot protection from falling or rolling objects that could crush or break toes. The toe-cap is designed into the safety shoes at the time they are manufactured.

There are two classifications for impact ratings--Classes 50 and 75:

• I/50 resists 50 pounds dropped from 12 inches.
• I/75 resists 50 pounds dropped from 18 inches.

What do these figures mean? I/75 rated toe-caps must pass a foot-pound test by dropping a 50-pound steel weight from a height of 18 inches. This is measured in foot-pounds and will protect a worker from an impact of 75 foot-pounds.

There are two classifications for compression ratings--also Classes 50 and 75. The shoes are tested to withstand compression at a set poundage before the toe-cap begins to crack or collapse:

• C/50 = 1,750 pounds
• C/75 = 2,500 pounds

The ASTM standard F2413-05 dropped a previous Class 30 rating from both impact and compression ratings. The standard also excludes "hang-on" or "strap-on" toe-caps, which are added on to the shoe. The toe-cap must be an integral, built-in part of the footwear. Also, the standard has removed static dissipative (SD) type II shoes, leaving only type I.

Read the Label
Here is a sample of a label you might find in safety footwear:

That code breaks down in this manner:
ASTM F2413-05 is the ASTM standard.

M I/75 C/75:
M or F identifies the gender (M = Male or F = Female)
I/75 is the impact resistance rating.
C/75 is the compression resistance rating.

PR
This line identifies protection from other types of hazards, including:
Cd = Conductive properties
CS = Chainsaw cut resistance
DI = Dielectric insulation
EH = Electrical insulation properties
ESD = Electrostatic dissipative
PR = Puncture resistance
SR = Slip resistance

The List Goes On
That list of ASTM initials reminds us that feet in the workplace can be injured in a great variety of ways, so many factors need to be taken into consideration. Slip resistance, for example, is a factor employers need to ponder. Are employees in danger of slipping on slick surfaces? OSHA requirements for fire brigades, in 1910.156(e)(2)(ii), call for Class 75 footwear that is water-resistant for at least 5 inches above the bottom of the heel and equipped with slip-resistant outer soles.

Electrostatic dissipative shoes, which reduce the accumulation of static electricity, should be worn around sensitive computer equipment so the machines do not receive static shocks. To prevent potentially dangerous sparks, they should also be worn where an explosive atmosphere, such as flammable vapors, may be present.

Protective footwear with puncture protection would be required where sharp objects, such as nails, screws, or scrap metal, could be stepped on by employees. Also, workers in settings that include garbage, such as landfills, should wear shoes with puncture protection to prevent the possibility of being stuck by infected needles.

Protective footwear for workers climbing ladders also should have defined heels and solid shanks, a supportive component of shoes, to stop the feet from bending downward on the rung.

"Assessing the Need for Personal Protective Equipment (PPE)," from the OSHA Office of Training and Education, offers these additional protective options for feet (and legs, too):Leggings: These protect the lower legs and feet from injuries caused by heat hazards. These can include molten metal or welding sparks. Leggings can be removed quickly, if necessary, thanks to safety snaps.

Metatarsal guards: Made of aluminum, steel, fiber, or plastic, these guards can be strapped to the outside of shoes to protect the top of the foot from impact and compression.

Combination foot and shin guards: These guards can help provide greater protection when it is needed.

Ultimately, it's up to you to assess your workplace, determine the nature of existing hazards, address those hazards, and equip your workers accordingly. Remember, OSHA regulations have been created and are enforced to protect workers from harm. When regulations are followed and workers are supplied with the right PPE, multiple benefits result: fewer accidents, lower overhead costs, lower insurance premiums and worker's compensation expenses, and, ultimately, greater profits for the company.

Best of all, workers can go home at night happy and free of injuries, enabling them to look forward to another great day of workplace safety and productivity. That's one kind of happiness you don't need a psychoanalyst to find!

This article appeared in the October 2006 issue of Occupational Health & Safety.

This article originally appeared in the October 2006 issue of Occupational Health & Safety.