Protective footwear is tested with a number of criteria, including impact and compression, puncture, heat, cuts, electrically conductive, static, and traction.

My Feet Are Killing Me!

Mr. Safety, be sure to create those relationships with your front-line managers and production employees and conduct a complete hazard assessment.

Here lies yet another article regarding foot protection in the workplace. One would think that, for as long as this standard has been in place, we would find every workplace in compliance and experiencing fewer foot injuries than in previous years. Working as a consultant the past few years, however, I have continued to visit facilities where foot protection is neither provided nor worn, leading to a continuance of foot injuries. And in 2010, foot injuries made up 25 percent of all reported disabling injuries!

In addition to the direct injury costs from not wearing protective footwear -- not forgetting the employee's costs associated with healing and recovery -- there are numerous other costs associated with not selecting the proper footwear, which leads to foot conditions that end up requiring expensive medical attention. These costs do not always get "recorded" because the employee actually cannot file a work injury as occurring at a specific time. Rather, it creates a more chronic foot condition from wearing inadequate footwear. These conditions do, however, impact the employee’s ability to fully perform the tasks for which the employee was hired. As a result, the employer also feels the impact from reduced work output and increased absenteeism.

When (maybe I should say, "If") an employer conducts the required hazard assessment for determining what PPE must be put in place, consider a more complete assessment of foot protection that goes beyond whether an employee risks having something land on his foot. Getting this one right the first time will ensure better overall performance and profits even though it may appear a little more expensive upfront.

Here are some of the considerations concerning protective footwear. Knowing that a hazard exists should certainly provide clear guidance to implement a policy around wearing protective footwear. Common injuries for no or inadequate footwear include crushed or amputated toes or feet, punctures, cuts, burns, shock or electrocution, and sprains, strains, and fractures.

Additionally, starting off with ill-fitting footwear complicates problems by causing blisters, walking pain, potential hip and back dislocations and pain, corns and calluses, malformed toes, arthritis, fallen arches, and fungal infections, to name a few. Any of these problems can result in the employee needing time off for appointments and treatment, changes in work assignments, higher absenteeism, lower overall performance, and even job endangerment if the employee is unable to perform at the expected levels – all a result of the wrong shoe or boot.

The Value in Employer-Provided Footwear
With the relatively recent OSHA "clarification" on employers purchasing PPE for employees, we continue to hear the argument that footwear may be considered a "personal" item that eliminates the need for an employer to purchase it. Unless there are specialty footwear requirements, that argument may be valid. The problem lies in that the employee is now left with a couple of options. One, find the cheapest protective footwear possible to comply with the employer’s request to wear it; two, just ignore the hazard and continue wearing "work boots" and hope everyone is lucky today and no one gets hurt.

I have experience dealing with employees who developed foot problems as a result of "specialty" footwear that was required in our facility. When they brought it to the company's attention, it became a worker's compensation topic. We set up appointments with foot specialists and even paid for physician-prescribed custom-designed footwear for a couple of employees. The employees were grateful that the company showed concern, took the responsibility to address the problem, and eliminated the need for ongoing or extended treatments.

From that experience, I also learned it was far less expensive for me to research and identify the best footwear for our needs and cover the purchase of that footwear rather than sending employees to get their own with a reimbursement program or an allotted amount of cash. Even then, we had to deal with additional issues -- working, walking, and standing on a variety of ground and floor materials, such as concrete, asphalt, steel grating, and platforms. We used a wet process, so we always had a mix of wet and dry flooring and stairs, followed by weather-related issues that included seasonal snow, ice, sand, and other slip-and-fall traction concerns.

Since slips and falls rank high among the cause of injuries, remember that one type of sole does not work for every situation in the workplace. Identifying the one type that works the best overall or by purchasing different types for specific departments and applications are ways to minimize traction and fall hazards. If the employer is not thinking about this as part of the selection process, though, it often gets ignored or missed until the high-cost injury occurs.

Now that we understand that decisions around foot protection go much further than simply having the employee pick out a shoe he likes or can afford, here are some considerations and reasons for making a more complete assessment related to protective footwear.

At the outset, foot injuries and chronic foot conditions that are not addressed early on can become very expensive in treatment, time, money, and employee performance. Being an employer that does not require protective footwear when hazards may be clearly present sets the employer up for not only a high-risk injury, but also all the fallout addressed above. Going beyond the basics and assuming that you who are reading this are much more conscientious about this topic, there are "hidden" considerations, as well.

Footwear Testing and Sizing
Protective footwear is tested with a number of criteria: impact and compression, puncture, heat, cuts, electrically conductive, static, and traction, to name a few. Other factors include specific applications to address wet conditions (waterproof) and temperatures (hypothermia and freezing or high-heat applications).

Footwear also is identified under ANSI standards as to whether it is for a male or female. Many facilities purchase one style shoe or boot in a variety of sizes, with women selecting the appropriate men's size. This is a common mistake. Though sometimes the sizing can be adjusted, the best fit and least amount of complications come when a female employee selects footwear designed for the female foot.

There are obvious limitations to protective footwear. For example, generally the best foot protection available for general industry has a ANSI impact rating of 75, meaning it has been tested by dropping 75 pounds on the toe from a height of 18 inches. This is not bad, but when the risk of something falling on a foot is five tons, the employee begins to realize that not getting under a suspended load is a practice that is as important to maintain to keep his feet functional as to keep him alive.

As a side note, this often brings up the discussion by an employer for not providing or requiring protective footwear in the first place. After all, goes the argument, nothing will stop that five tons from crushing a foot and having a steel toe cap cut through the toes from that much weight is not really safer for the employee, right?

If we follow that logic, then I suppose we don't need arc flash protection since we don't have clothing that will survive a 3,000 F degree flash; we don't need a hard hat since we have 12-ton steel beams overhead; we don't need work gloves since we have 50-pound boxes that could fall on our fingers. Really?

Another factor for which employers and employees have control is related to housekeeping. If there is ice near the door, melt it. If there is hydraulic oil on the floor, clean it up or absorb it. If hoses are placed between stair treads, the traction value of footwear doesn't really matter if people trip or become entangled in it. Housekeeping accounts for 70 percent of all injuries in the workplace, so getting this little item addressed and in order will go a long way toward minimizing injuries and eliminating hazards.

Responsibility and Accountability
Finally, let's talk responsibility and accountability. I do not endorse the position the government takes that all managers are responsible and employees can do what they want without any repercussions. I do agree that managers and employers have far more responsibility than they are often willing to take, as if there were a choice. The manager already has the direct legal responsibility, whether "accepting it" or not.

That said, take a few minutes and review your current footwear position and program. Taking responsibility for this will reduce what we haven’t discussed: liability. And, not to forget that your employees are your most valuable asset, the money and feeling of impending guilt and doom are just part of the ongoing consequences.

Mr. Safety, be sure to create those relationships with your front-line managers and production employees and conduct a complete hazard assessment. It will help you make a much better decision on how you can actually help and improve the safety of your people, regardless of compliance. In addition, actually knowing the processes and procedures that your people must follow never hurts. Taking the opportunity to learn the process and not simply quote compliance makes your life easier, and you create a win-win for yourself and your people.

This article originally appeared in the April 2012 issue of Occupational Health & Safety.

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