Footwear in Focus

The starting point when selecting protective footwear is a Job Safety Analysis to understand the hazards that are present in a given workplace.

According to OSHA’s general industry foot protection standard, at 29 CFR 1910.136(a), “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 references ASTM F-2412-2005, Standard Test Methods for Foot Protection; ASTM F-2413-2005, Standard Specification for Performance Requirements for Protective Footwear; ANSI Z41-1999, American National Standard for Personal Protection — Protective Footwear; and ANSI Z41-1991.

Worth noting is that these standards have been by now been superseded or, in the case of Z41-1999, withdrawn. F2412-11 and F2413-11 are the current versions of the first and second ones listed, which replaced the withdrawn Z41 standard some eight years ago.

Thus, the key footwear standards to be aware of are maintained by ASTM’s Committee F13 on Pedestrian/Walkway Safety and Footwear (www.astm.org/COMMITTEE/F13.htm) . They address test methods for impact resistance, compression resistance, metatarsal protection, puncture resistance, electrical hazard, as well as the design, performance, and testing of protective footwear. F2412 also states that safety-toe footwear specimens or samples are to be retested for changes such as a change in the design of or material used to make the protective toe cap, a more than 25 percent change in the thickness of the upper or insole material, a change in the hardness of the outsole, or a change in the material or supplier of the metatarsal guard.

When evaluating safety footwear, ask whether the shoe or boot reduces risk in the work environment where it will be worn -- that is, the risk your Job Safety Analysis has determined is present. Does it fit comfortably? Is it durable? Not that you can reasonably expect safety footwear to last forever; you should remind employees to evaluate their safety-toe footwear and other protective types regularly to ensure it is still doing the job in terms of puncture resistance, traction, and other protective characteristics.

Typical Foot Injuries

There are two major categories of foot injuries: those caused by punctures, crushing, sprains, and lacerations; and those that result from slips, trips, and falls. Various types of protective footwear specified in the OSHA and ASTM standards are made to protect against these injuries, but experts in this area also recommend evaluating the workplace to minimize or eliminate the hazards where possible. Some floor surfaces can be made less slippery, and companies should make it a priority for workers to report and clean up all spills promptly, preventing visitors and employees from slips and falls. This is critical for retailers in particular.

Sprains and strains often result from slips and falls, walking or running on uneven surfaces, and sometimes from dismounting from heavy equipment. Foot fractures can be caused by impacts from dropped tools, working too close to mobile equipment, and also falls from height. It has been reported that about 10 percent of all occupational injuries in the United States are foot- and ankle-related, with construction, manufacturing, and service industries accounting for the majority of all such injuries.

The Bureau of Labor Statistics reported last November in its summary report on 2011 non-fatal lost-time injuries in the private sector that falls, slips, and trips caused 20 percent of all such injuries for nursing aides, orderlies, and attendants; 29 percent of them for janitors and cleaners; and 30 percent of them for drivers of heavy trucks. Combined, these three job categories accounted for 136,810 lost-time injuries during that year, BLS reported.

Who Pays for the PPE?

Manufacturers and distributors are good sources of information about footwear options and pricing. OSHA published new enforcement guidance for PPE in February 2011 in part to help employers understand which types of protective equipment the agency says they must pay for. The OSHA final rule for Employer Payment for Personal Protective Equipment became effective Feb. 13, 2008.

It said employers “must provide, at no cost to employees, metatarsal guards
attachable to shoes when metatarsal protection is necessary (29 CFR 1910.132(h)(2)). If metatarsal protection is necessary under OSHA standards, and an employer requires employees to use metatarsal shoes instead of detachable guards, then the employer is required to provide the metatarsal shoe at no cost to the employee. If the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, then the employer is not required to pay for the metatarsal shoes or boots.”

The same document said employers aren’t required to pay for non-specialty, safety-toe protective footwear if they allow employees to wear it off the job site, nor do they have to pay for logging boots. 

References

1. Common Foot and Ankle Injuries, Midwest Orthopaedics at Rush, LLC, Chicago, Ill.  http://www.rushortho.com/ot_foot.cfm

2. OSHA Instruction, Enforcement Guidance for Personal Protective Equipment in General Industry, http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-050.pdf

This article originally appeared in the July 2013 OHS issue of Occupational Health & Safety.

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