Time to Change?

How do you know when your protective footwear needs to be replaced? We ask the experts.

WHEN it comes to a foot protection program, many employers think once their employees lace up a task-approved boot, their program is complete. While these employers might deserve a pat on the back for doing this much to protect their employees' feet, they've really only just begun.

In 1994, OSHA published revisions to its personal protective equipment regulations. Included in this revision process was the agency's standard pertaining to foot protection, 29 CFR 1910.136. The major emphasis of the standard is found in paragraph (a), General Requirements: "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."

The standard requires that protective footwear comply with ANSI Z41-1991, which breaks footwear down into six categories: Impact/Compression Resistance, Metatarsal protection, Electrical Hazard protection, Conductive footwear, Puncture-Resistance, and Static-Dissipative footwear. Safety footwear that meets ANSI requirements is labeled ANSI-approved with ratings for each of the applicable six categories, making it easier than ever for employees/employers to match their foot protection needs with the appropriate shoe.

But purchasing and even wearing the right protective footwear is not enough. OSHA also requires that all employees be trained in the care, maintenance, and disposal of PPE. Footwear is no exception. Knowing when a shoe has reached the end of its useful life and needs to be replaced is just as important as choosing the proper one to start with.

Impact and Compression Resistance
ANSI requires all approved footwear to offer impact and compression resistance. This protection is primarily provided to the toes by use of a "toe box" that is built into the shoe at the time of construction and is designed to protect the toe area of the foot from falling or rolling objects. There are three levels of protection available for impact and compression resistance: Class 30, 50, and 75. Class 75 is the highest level and is recommended for most applications.

While this is often the only protection provided by "ANSI Approved" footwear, it is often one of the more difficult when it comes to determining when it needs replacing. Chris Wojnar, product development manager for LaCrosse Safety and Industrial, said this type of footwear should be replaced after any impact, especially if the wearer can detect a dent in the steel toe. "If you are unsure that your footwear has been compromised, it can be X-rayed to determine if damage has occurred that will require replacement," Wojnar said. "But X-raying is not done often, and only at the user or contractor's discretion."

Because the impact standard of a safety toe cap may be reduced by an impact and not show physical signs of damage, Wayne Elsey, CEO of Footwear Specialties International, recommends wearers take a proactive approach. "If a shoe gets hit by any force at all, you should replace it," he said. "You don't know what damage has occurred."

In addition to replacement after an impact, Elsey recommended that this type of footwear be replaced if any part of the steel toe becomes visible. "The toe should continually be covered. You shouldn't be able to see the steel toe at all," he said.

Shoes with an outsole pattern that has worn away also should be considered for replacement, because the impact compression standard could be reduced.

Metatarsal Protection
Footwear with metatarsal protection is designed to protect the wearer's upper foot (metatarsal bones) and toe areas, particularly when these areas are exposed to drop hazards. Metatarsal protection is also available in three levels of protection: Class 30, 50, and 75. To be compliant with the ANSI standard, the metatarsal guard must be an integral part of the shoe, incorporated into the shoe during manufacturing. External and internal metatarsal designs are available.

Similar to the replacement recommendations for impact- and compression-resistant footwear, metatarsal footwear should be replaced after any impact to the metatarsal guard, said Christina Vernon, assistant marketing manager for Wolverine Boots and Shoes. "It's also time to replace your shoes if the metatarsal guard's leather or exterior covering is torn," she said.

Conductive Footwear
Conductive footwear provides the wearer protection against the hazards of static electricity build-up by discharging static electricity from the body through the shoes into grounded floors. This footwear is classified into two groups: Type 1 and Type 2.

Type 1 conductive footwear is designed to minimize static electricity, reducing the possibility of ignition of volatile chemicals or explosives in dusty, chemical, explosive, and other flammable applications.

Type 2 footwear is designed to protect employees working on high-voltage lines by aiding in equalizing the electrical potential of the employee and the energized high-voltage lines. However, this type of footwear should not be worn near open electrical circuits or highly charged objects.

In determining when to replace conductive footwear, "you're looking at the sole, which is really what matters," Elsey said. Throughout the life of conductive footwear, the user should take care to keep the soles clean and free of contaminants that may affect conductivity, such as nails, screws, and metal shavings.

Elsey said work sites that require conductive footwear typically have a testing machine on site for footwear conductivity tests. "It is usually used every day before going into this type of environment," he said.

Conductive footwear should be disposed of and replaced when the soles become contaminated and/or when the shoe no longer tests conductive.

Electrical Hazard
Electrical hazard footwear is designed to provide extra protection where accidental contact with electrically energized objects is possible. The soles of electrical hazard shoes are designed to reduce the potential of electrical shock when exposed to open circuits of 600 volts AC or less. They also provide secondary electrical hazard protection on substantially insulated surfaces.

Electrical hazard safety shoes should be kept dry and free of conductive materials. They need to be replaced if the sole is punctured, cut, or embedded with conductive materials. Because the shoe's sole is of such importance, it should also be replaced when significant wear diminishes the thickness of the sole. There is no set amount of time that a sole will remain effective. "How it wears depends on a person's body weight and the way they walk," Elsey said. "It's going to be different for everybody."

Puncture Resistance
Puncture-resistant footwear includes a puncture-resistant protective device that reduces the possibility of puncture wounds to the feet from sharp objects penetrating the sole. To meet ANSI standards, the protective plate must be an integral part of the shoe. This type of footwear is commonly found on construction sites or other areas where nails, staples, and other sharp objects may be on the ground.

A shoe with puncture resistance has reached the end of its useful life when an object becomes embedded in the puncture resistant device. At this point, the footwear should be replaced. "It really should be common sense," Elsey said.

Static Dissipative Footwear
Static dissipative footwear is designed to provide protection from electrical hazards due to excessively low footwear resistance, or the accumulation of excess static electricity, while still maintaining a high enough level of electrical resistance to protect workers from electrical hazards.

As with conductive and electrical hazard footwear, the sole of static dissipative footwear is key and should be kept clean. Static dissipative footwear should be replaced after the soles become contaminated or when it no longer tests static dissipative.

"With static dissipative, conductive, and electrical footwear, you don't want to question or even think about whether or not to replace a shoe," Elsey said. "Just replace them frequently."

Chemical Resistance
Designed to protect the feet from chemicals used during everyday work tasks or emergency spill cleanup, chemical-resistant footwear is usually made of rubber or PVC. Wojnar said leather also is sometimes used for these applications, "but current leather tanning technologies do not allow for advanced chemical compounding."

Regardless of its composition, chemical-resistant footwear should be replaced if it is discolored, showing signs of delamination or swelling, or exhibits any breaks, cracks, or other surface degradations.

A microscopic tear or specific exposure has the potential for jeopardizing the effectiveness of this type of footwear, so wearers should not rely purely on a visual need for replacement. "A hazmat boot, for example, may not show any physical signs that its protective qualities have been compromised by chemical exposure," Wojnar said. "As a result, this type of footwear should be inspected and replaced as often as needed."

Slip Resistance
In addition to providing protection for employees' feet, many employers rely on protective footwear, specifically slip-resistant footwear, to prevent other workplace injuries caused by slips, trips, and falls.

Like the many other job-specific footwear types, the sole is the most important component of slip-resistant footwear. While somewhat scuffing up the soles of new shoes may reduce slipperiness, a lot of tread wear will diminish slip resistance. Wojnar recommends monitoring the rear two-thirds of the heel, an area key to slip resistance.

Elsey said the shoe should be replaced when the sole begins losing its original characteristics. "Sole wear is key to the functionality of it--less tread, less performance, just like a tire," he said. "A sole is going to need replacing when it's flat and slick-looking."

The Comfort Factor
If an employee's feet are hurting, his body will soon follow and so will his productivity. In addition to monitoring for other compromising signs of wear and tear, it's important that protective footwear be replaced when it is no longer comfortable to wear.

"Consider a product with a replaceable insole," Elsey recommended. "The insole should last a few months, at best, and should be replaced to make the product as comfortable as when originally purchased." If new insoles don't bring the user the original level of comfort, the entire shoe should be replaced, he said.

Additional comfort factors should be considered for employees working in harsh environments, particularly with protective toe caps, Wojnar added. "If an employee is working in a cold environment, it is important that the steel toe is properly insulated to prevent transmission of the cold," she said. "In the case of a composite or fiberglass toe, there is less likely of a chance that cold will be transmitted, and if insulated, it will add comfort for the employee."

Getting It Done
Ensuring your employees wear the proper protective footwear is not an easy task, and seeing that they replace their footwear when necessary is even harder. While employers can require their employees to wear foot protection, they are not required to provide it. Unlike other PPE, protective footwear is often worn away from the job by employees who expose it to additional wear and tear, making it nearly impossible for employers to monitor for replacement.

To best ensure that employees are maintaining and replacing their footwear as necessary, Wojnar recommends physical inspections after every accident and periodic inspection of shoe outsoles.

Yet even upon the employer's recommendation, the personal cost of replacing protective footwear may make employees hesitant to comply. To ease the financial burden, many employers offer shoe subsidy programs that pay for a portion or the entire price of new footwear. "Those are the companies that are truly concerned about their employees and have strong safety programs," Elsey said. "They realize the price of new shoes is small in comparison to the cost of an injury."

Regardless of who covers the cost, protective footwear must be replaced in order to remain effective. "Some people think products last forever, but they do not," Elsey said. "With job specific footwear, you need to maintain and replace as needed, without hesitation. When in doubt, throw it out and replace."

1. Brickman, Charles. "Heart and Sole." Occupational Health & Safety, April 1999.
2. Standards We Live By, Footwear Specialties International. www.footwearspecialties.com.

This article originally appeared in the July 2003 issue of Occupational Health & Safety.

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