Toeing the Line

Foot and toe injuries in manufacturing and construction dropped significantly from 1998 to 2002, BLS reports.

• By Jerry Laws
• Apr 01, 2005

INTERESTINGLY, it may be perfectly acceptable to wear tennis shoes while installing sheet metal weatherproofing on a steeply pitched roof. At least, that was the thrust of a May 2004 interpretation letter from the chief of OSHA's Construction Directorate. Director Russell Swanson's letter said 29 CFR Part 1926 Subpart M (Fall Protection) did not require or prohibit wearing tennis shoes in these circumstances.

Employees working on steep roofs with unprotected sides and edges 6 feet or higher above lower levels must be protected by guardrails, safety nets, or personal fall arrest systems, but the standard specifies no specific type of footwear that must be worn. "There also is no prohibition in the standard against the use of tennis shoes in this circumstance," he wrote. "We note also that in view of the wide variety of sheet metal surfaces and variety of types and condition of 'tennis shoe' material, we cannot comment on the extent to which such shoes would add or detract from a worker's chance of slipping on metal sheeting. Similarly, because of the wide variety and condition of material used for boots (both for the soles and for the rest of the boot), which have varying characteristics for both flexibility and degree of slip resistance, we cannot comment on whether the use of boots in this situation would be more or less of a problem than tennis shoes."

Fortunately, whether mandatory or not, safety shoes or boots obviously are overwhelmingly accepted and regularly worn by construction workers, just as they should be. The Bureau of Labor Statistics reports 60,000 nonfatal injuries in 2002 involved workers' feet and toes, with services (11,600) and manufacturing (10,900) accounting for more of these than retail trade (10,500) or construction (8,400). Foot and toe injuries were a fairly small portion of the nation's 2002 workplace injury toll, accounting for only 4.2 percent of the 1,436,000 lost-time injury cases in private industry that year.

Given that private industry workers sustained about 85,000 foot and toe injuries in 1998, the picture is definitely improving. Manufacturing and construction accounted for 33,000 of those injuries in that year, so the BLS figures represent a 42 percent decline in those sectors' foot injuries during that four-year span.

The lower number of foot injuries in construction is encouraging but not surprising. The International Safety Equipment Association's 2004 survey asked safety leaders how personal protective equipment is used in heavy construction, and safety shoes and boots ranked second only to hard hats in having the highest rate of regular use--nearly 75 percent, a slight increase from the usage rate shown in ISEA's 2001 survey. (Strategic Marketing Associates of Stow, Ohio, conducted the surveys for ISEA.) Regular use of most types of PPE types investigated in the surveys continues to rise, the association reports, with hard hats, safety footwear, and high-visibility safety vests ranking highest in both 2001 and 2004.

The Gap is Closing
OSHA noted in 1992 that only about 25 percent of workers who suffered a foot injury were wearing safety shoes or boots when they got hurt. The wide gap back then between footwear use in the field and what the agency's construction (29 CR 1926.26) and general industry (29 CFR 1910.136) foot protection standards demand has been closing, the BLS statistics suggest.

The general industry standard says employers "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." Both standards say the protective footwear must comply with ANSI Z41.1, American National Standard for Personal Protection--Protective Footwear. Footwear that meets this standard's 1999 edition will bear a mark indicating it complies with Z41.1.

Sizing Up the Hazards
Your footwear program starts with a hazard assessment. In many settings, impact hazards are the primary concern. Footwear with impact protection should be worn in work areas where employees carry or handle packages, parts, or heavy tools, and in any areas where they engage in other activities where objects might fall onto their feet.

Footwear with compression protection is required for work activities involving forklifts, pallet jacks or skid trucks, or other material handling equipment that could roll over an employee's feet.

Footwear with puncture protection is required wherever sharp objects--e.g., nails, wire, tacks, screws, large staples, scrap metal, metal shavings, etc.--could be stepped on by employees and thus cause a foot injury. Employees working with corrosive chemicals, caustics, cutting oils, or petroleum products should wear footwear made to prevent penetration by these substances; electrical hazard footwear is available.

You can use the following checklist to evaluate your program and eliminate gaps in your own safety footwear program. Manufacturers and distributors are excellent sources of information about proper care and fitting, protection against specific hazards, and how to evaluate workers' footwear to detect damage or wear signaling the shoes/boots should be replaced. Checklists are just a guide and cannot substitute for a current, well-administered program.

Checklist for Foot Protection
This checklist was compiled by Linda F. Johnson, a former technical editor of Occupational Health & Safety. It is not intended to substitute for a comprehensive safety program.

• Do all exposed employees wear protective footwear when necessary?
• Are all foot protection items maintained according to the manufacturers' recommendations?
• Are employees instructed on the types of hazards that may cause foot injuries and on preventative measures?
• Does your written foot protection program require employees to report injuries, and do they know how to report them?
• Are program elements enforced and reviewed on a regular basis?
• Is your foot protection selection based on a documented hazard assessment?
• Is there a documented review of employee-owned or provided footwear?
• Is there a policy stating defective or damaged foot protection must not be used and must be removed from service?
• Do you take disciplinary action when employees do not adhere to the policy?
• Is your training complete and documented for all employees?
• Are scrap, debris, and waste stored safely and removed from the work site properly?
• Are aisles and passageways kept clear from tripping hazards?
• Are wet surfaces covered with non-slip materials?
• Are changes of direction or elevation readily identifiable?
• Are aisles or walkways near moving or operating machinery, welding operations, or similar operations arranged so employees will not be subjected to potential hazards?
• Are step risers on stairs uniform from top to bottom?
• Where the ground or surface is wet underfoot, do employees wear impervious boots, shoes, rubbers, or other appropriate shoes?
• Is waterproof footgear provided or are dry places provided for standing during wet processes?

This article appeared in the April 2005 issue of Occupational Health & Safety.

This article originally appeared in the April 2005 issue of Occupational Health & Safety.