An End to Crushing Defeats

Use the hierarchy of controls to ensure workers' feet are well protected against impact hazards.

• By Fred Elliott
• Apr 07, 2008

OSHA’s recent guidance document for protecting against the skin ailments related to portland cement exposure was a handy reminder that impact hazards are not the only one to be addressed by your foot protection program. Bricklayers, carpenters, laborers, concrete finishers, ready-mixed concrete truck drivers, and other workers who may be exposed to wet cement need waterproof boots to prevent contact with their skin, and some crafts also need waterproof kneepads or dry kneeboards so their knees won’t touch wet cement when they’re kneeling on it. Skin care is a must in these circumstances.

Protection against impact and crushing hazards is our topic for today, however. These hazards can come into play for construction work of all kinds, and also for warehouse and delivery work, law enforcement and emergency response, shipyard jobs, and many more.

An effective impact protection program follows the standard hierarchy of controls:
• Elimination
• Substitution
• Engineering controls
• Administrative controls
• Personal protective equipment

It’s fairly easy to see how to apply the hierarchy in most settings. A crushing hazard posed by manual movement of heavy, wheeled carts could be averted by substituting a different type of cart, changing the cart movers’ travel paths so other workers don’t have to cross those paths or step into them from behind walls and other obstructions, or installing rigid barriers to prevent visitors and personnel from stepping into the path of a cart. All of these could be done simultaneously; the movement of materials also could be automated, perhaps by use of a conveyor, which is a costly correction that presents a different set of worker hazards.

Safety professionals know that the controls at the top of the hierarchy are more effective and more protective than those at the bottom. Following the hierarchy will bring about inherently safer operations that reduce costs, in most cases. Elimination and substitution are the most difficult to implement in existing processes, where administrative controls and PPE are more frequently used if the hazards are not well controlled, NIOSH has noted.

If the less expensive option is chosen, the fifth and final level in the hierarchy is sure to be part of the solution. The cart movers need protective footwear and those working near them probably will, too. This footwear should meet the ASTM F2413-05 standard, which addresses minimum requirements for the performance, design, testing, and classifications of protective footwear. (The related ASTM F2412-05, Standard Test Methods for Foot Protection, specifies the protective qualities that toe and metatarsal impactresistant footwear should have against falling objects and compressive forces. Visit www.astm.org for more information.)

Preventing Crushing Injuries
Steel-toe footwear—a hot topic in safety since this category was exempted from OSHA’s “employer pays for PPE” rule earlier this year—is the basic, essential element in PPE to prevent foot crushing injuries. The footwear should be chosen to match workers’ exposures, and it’s possible there are multiple exposures (slip hazards come to mind) for which footwear must be carefully evaluated and selected. Make sure to involve the employees in your hazard analysis and PPE selection; they know the hazards of their work better than anyone else.

Crushing injuries may result from a dropped or toppling object or inattention. They can happen when someone’s foot is caught in a crack or crevice and struck. Moving equipment and vehicles are additional hazards.

OSHA’s general industry standard for occupational foot protection is 29 CFR 1910.136. Not only can you find its text easily on www.ohsa.gov, but also you’ll get the relevant Standards Interpretation letters OSHA has issued referencing it. It’s important to note that the standard leaves protection decisions up to the employer, but it does require that protections be in place if employees are exposed to specific types of hazards—however infrequent that exposure may be, OSHA has said. The standard tells employers to “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.”

It should be made clear to employees that they are responsible for telling their supervisor when there’s a problem. Supervisors are responsible for employee compliance with the employer’s work rules, for counseling employees about hazards and PPE to guard against them, and for documenting non-compliance when it occurs.

This article originally appeared in the April 2008 issue of Occupational Health & Safety.