Step by Step

Take these 11 steps to ensure your employees' footwear is up to par.

DID you know foot and toe injuries typically take longer to heal than many other common workplace injuries? In fact, according to the U.S. Department of Labor's Bureau of Labor Statistics, employees who suffer a foot or toe injury miss an average of seven days of work. This is in comparison to an average of five sick days as a result of a hand or finger on-the-job injury.1 The National Safety Council reports 180,000 foot injuries on average occur per year, which is about 500 cases per day.2 Imagine if each of these resulted in seven days of missed work--more than 1,260,000 production days could be missed annually!

"Each time an employee is out of work due to injury, the company doesn't just incur the monetary cost of the accident, but the loss of time, production, and training due to the employee's absence," said Don Stallings, who is the national account manager for a national safety footwear distributor. "But at nearly $6,000 per injury, foot and toe accidents aren't cheap, either."3

However, employers should also keep in mind that a properly implemented personal protective equipment program will help to reduce some of those costs. Reducing accidents by 10 percent can result in an annual savings of nearly $60,000. "Making sure that employees are properly protected against potential foot and toe injuries and in compliance with safety program requirements can also help lower insurance premiums by improving a company's worker's compensation mode rating," said Stallings.

OSHA requires every employer to conduct a hazard assessment--this is found in 29 CFR 1910.132(d)--to determine workplace risks, including foot injury hazards. The complete hazard assessment then allows a company to determine the appropriate types of PPE required for each employee's specific duty. "It is recommended that the safety professional at each work site partner with a safety footwear manufacturer's representative or safety footwear distributor. Together, they can view and evaluate each different working environment within an employer's operation to determine the various hazards that could cause a foot or toe injury," Stallings said. "For example, potential falling objects, moving equipment, slippery surfaces, electrical hazards, impact hazards, etc. It is then the responsibility of the employer's safety director to recommend and implement a safety footwear program based on the results of the evaluation."

Once the PPE evaluation is complete and a safety plan is in place, there is one additional key component to ensuring employee safety, especially in the case of foot protection: "Inform, train, and empower employees to choose and maintain proper safety footwear," said Pete Pittelkow, president of HyTest Safety Shoe Service. "Statistics show that 75 percent of foot injuries occur when employees are not wearing PPE compliant footwear. If employees are committed to the company's safety plan and safety footwear requirements, their efforts can drastically help reduce workplace foot and toe injuries."

Training and Education
OSHA requires that employers train all employees who must use PPE. In regards to footwear, training should cover: when PPE is necessary; what type of PPE features are necessary; how to properly choose, adjust, and wear the safety footwear; limitations of the footwear; and proper care and maintenance.4

The following steps can be used as a guideline to help develop a company's personalized PPE footwear training plan.

1. Schedule employee group meetings. Workers who have jobs with similar risks and PPE footwear needs should be grouped together for training sessions. The training sessions should be thoroughly planned out in advance, with materials and agendas on hand. "A company's safety professional should conduct the training sessions to inform the employees of the hazards that are present in their particular working environment," said Stallings. "Because there are so many hazards that could be present in each job, discuss each group's job-specific hazards and associated foot injury risks in detail."

2. Discuss the variety of footwear safety features available. Describe what type of protection is key to being safe in the presence of each hazard. Fully explain the protection provided by each component. Be sure employees are aware that there are desired and not-so-desired footwear safety components for each type of work being done. For example, electrostatic dissipating footwear may be required in some work environments but would not be safe in others.

3. Demonstrate proper fit. Have a trained professional fit each person for the proper shoe size. Wearing properly fitted footwear allows for correct ankle, knee, and lower back support, and it limits rubbing or blistering that might occur from ill-fitting work footwear.

4. Provide appropriate resources for employees to purchase required PPE footwear. Make sure employees understand the need to maintain compliance with ASTM F13 safety standards when applicable. Having a trained professional sell shoes on site can help ensure employees are buying durable, comfortable work footwear. In addition, this convenience will encourage employees to update or replace their footwear more frequently, helping to make sure employees are wearing safe footwear. In the alternative, companies can establish their own on-site store to meet these needs.

"Having a knowledgeable staff person at the job site can also help in the event an employee has questions about footwear or what to do if he thinks the footwear's safety may need to be reevaluated," Pittelkow said. "This could be the job of the company's safety representative or another properly trained employee."

5. Demonstrate proper footwear care. Cleaning and maintaining footwear are paramount to a work boot's longevity and the employee's safety. Advise employees to consult the work boot's manufacturer's instructions or contact a footwear distributor to determine cleaning needs. Best care practices include brushing off dust and debris each day, as well as cleaning off excessive mud from the outsole and uppers.

Because moisture is a major cause of foot discomfort, such as blistering and cracking, work boot manufacturers recommend that employees have two pairs of footwear that meet job specifications. If a person works in a very active job where he/she is moving most of the day, the foot can perspire up to 200 ml of moisture each day.

6. Make sure employees know when footwear needs to be replaced. Encourage employees to periodically examine their footwear for any unusual wear. If the outsole is getting worn or is beginning to look uneven from wear, the slip- or heat-resistant qualities may be compromised, thus putting that employee in danger. Also, if a heavy object is dropped on the toe of a safety-toe work shoe, that pair should be replaced. Even if the employee was not injured in the accident, the shoe may have been damaged beyond what can be seen at first glance by the wearer.

7. Talk to employees about foot care. Wearing comfortable shoes outside of work and also taking care of feet can help prevent undue strain and foot fatigue on the job. Employees should check their feet regularly for any problems, such as cracks, corns and calluses; visiting a podiatrist or having feet examined by a medical professional should be a part of an annual medical physical.

8. Document your training. Employers are required by OSHA to create a training certification for each training or retraining session held. This certification should include names of employees trained, as well as the date and specific subject matter of the training session.5 Part of this documentation should include proof that employees understand workplace hazards and the company's PPE footwear regulations. Quizzing employees with a few basic questions at the completion of each training session is recommended to ensure knowledge.

9. Conduct periodic compliance reviews. Involve employees in an ongoing foot protection and hazards evaluation. Continue to ask employees to monitor their workplace for additional risks. "The company should establish specific time intervals when each employee is reviewed on a regular basis to ensure that they are fully compliant with all of the company's established PPE requirements. This will help confirm with the employee how serious the company is about the program," Stallings said.

10. Stay current with footwear and industry trends. A safety officer or other employee should be assigned the task of monitoring product, industry, and PPE regulation updates. If industry standards change or new technologies evolve, meet again with each training group to provide updates and continuous audits of footwear performance. Inform employees of new choices in foot protection or new footwear technologies. Monitor employees to make sure their footwear is compliant with the new industry standards.

11. Offer safety compliance incentives. If there are no injuries in the workplace, employees are definitely to thank for a safety plan's success. Reward employees with interesting incentive plans to encourage a continually safe workplace. In addition, simply hanging posters that demonstrate these lessons can be very beneficial when keeping employees motivated.

"Employees who are properly trained and encouraged will be more likely to maintain a safe workplace. Empower employees with the knowledge and understanding of basic PPE footwear requirements, and you'll be well on your way to a safer workplace," Pittelkow said.

References
1. U.S. Department of Labor. Bureau of Labor Statistics Data Survey Query Output (2003) 1 p. Online. Internet. June 7, 2005. Available at www.bls.gov/data/.
2. National Safety Council. Internet. June 2005. Available at www.nsc.org.
3. National Safety Council.
4. U.S. Occupational Safety & Health Administration. Personal Protective Equipment (2003): 44 pp. Online. Available at www.osha.gov.
5. Occupational Safety & Health Administration. Available at www.osha.gov.

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

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

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