Putting Our Best-Protected Feet Forward

OSHA cited a Lancaster, Pa., landscaping business on Jan. 29. The company had notified OSHA that an employee suffered a double toe amputation when he lost control of a lawn mower he was operating on a wet, grassy slope.

• By Fred Elliott
• Oct 01, 2016

Start with the standards: OSHA's 1910.136 and ASTM's F2412-11, Standard Test Methods for Foot Protection, and F2413-11, Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear; the latter covering the minimum requirements for the design, performance, testing, and classification of protective footwear. They're the basis for maintaining a compliant program.

The F2413-11 standard addresses protective toe caps and impact resistance, conductive protection, as well as electric hazard resistance, static dissipative protection, and protection against punctures. Footwear certified as meeting it must be marked to denote the standard with which it complies, such as with specific ratings for impact resistance, compression resistance, and metatarsal protection and protection for other specific types of hazards.

Footwear manufacturers' websites and www.osha.gov are good sources for information about these key standards. Canadian safety authorities such as WorkSafeBC also are worth consulting and following. An excellent OH&S article earlier this year by Wolverine's Roger Huard pointed out the three protective attributes some footwear offers that do not involve ASTM ratings and testing procedures: waterproof, insulation against cold environments, and slip resistance.

Here's how the OSHA standard describes employers' responsibilities in this area: 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, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.

It goes on to list the standards that protective footwear must comply with and that are incorporated by reference into the OSHA standard.

Training, PPE, and Risk Assessment
NIOSH, too, offers guidance in a variety of resources, including the nail gun safety guide¹ it and OSHA developed for construction contractors. Nail guns were responsible for an estimated 37,000 emergency room visits per year in 2001-2005 in the United States, according to a study published in MMWR, and while more than half of reported nail gun injuries are to users' hands and fingers, "After hands, the next most often injured are the leg, knee, thigh, foot, and toes," according to this guide.

It recommends using full sequential trigger nail guns because unintended nail discharge from double fire can occur with contact triggers, and the same thing can happen from knocking the safety contact with the trigger squeezed when using contact and single actuation triggers.

I recommend reading the training and PPE sections of the guide in particular. They explain in detail:

• What material you should cover in safety training for both new and experienced workers.
• Explaining the main causes of injuries, instructions provided by tool manufacturers, and where the manuals are kept.
• Covering how to handle specific risks and why wearing PPE is required.
• Why they must report injuries and near misses.
• Your company's first aid and medical treatment policies and procedures.
• The importance of wearing impact-resistant safety shoes, which are typically required on construction sites.
• The value of other types of required PPE, including hard hats, vision protection, hand protection, and hearing protection.

Some recent OSHA citations emphasize the importance of assessing potential foot hazards—an employee operating a lawn mower on a wet slope is clearly at risk, it goes without saying—and then training and equipping workers with the proper PPE to prevent serious injuries.

OSHA clarified in May 2008 that employers must pay for some types of protective footwear that employees wear. The rule on employer payment for PPE said metatarsal foot protection and rubber boots with steel toes were two examples of PPE that employers must pay for, while they do not have to pay for non-specialty safety toe footwear (including steel-toe shoes or boots) if the employer permits the employee to wear them off the job site.

Serious injuries such as fractures and lacerations can occur when workers in construction, warehouses and distribution, transportation, and other industries are insufficiently protected against falling and rolling objects or punctures. There were 60,830 ankle and 52,070 foot lost-time injuries during 2014 in the U.S. private sector industries and local and state governments, the Bureau of Labor Statistics reported in November 2015; the median number of work days lost to all lost-time injuries that year was nine, and the ankle injuries equaled that number with nine median days lost, according to BLS, while five days was the median number lost because of foot injuries that year.

Foot fractures account for about 10 percent of all broken bone injuries that are reported in the United States. Foot fractures are frequently caused by jumping or falling from height, a dropped object, or a crushing impact. But impact is far from the only hazard to workers’ lower extremities. Hazards such as slips, temperature extremes, and electricity are common enough in some occupations that workers’ protective footwear should be selected with them in mind.

Safety professionals know well that PPE alone will not prevent all incidents or injuries. Employers must develop an effective safety program that identifies hazards, implements solutions (engineering and administrative controls are the first lines of defense), and involves employees through safety committees and other means to prioritize their own safety. The hazard assessment, PPE, and training help to ensure that hazards are minimized and workers comply with the employer's policies. Prevention and training are important keys to a successful safety footwear program.

Reference
1. http://www.cdc.gov/niosh/docs/2011-202/pdfs/2011-202.pdf

Recent OSHA Enforcement Actions
Foot Injury Results in Citations: February 2016
OSHA announced it cited a Lancaster, Pa., landscaping business on Jan. 29 for two willful, five serious, and one other-than-serious safety and health violations. The company had notified OSHA last August that an employee suffered a double toe amputation when he lost control of a lawn mower he was operating on a wet, grassy slope; this happened less than three months after OSHA investigated another rollover incident in which an employee sustained serious injuries and was hospitalized, according to the agency.

OSHA issued $42,000 in proposed penalties after its inspectors determined the company failed to ensure workers were using a rollover protective system and seat belts when operating the zero-turn mower. This brought the willful citation. Serious citations were issued because the company failed to use the proper guards on the mower and because of chemical hazards and the lack of a hazard communication program. The company was also cited for failing to prepare a written workplace hazard assessment.

Steelmaker Cited for Multiple Violations: February 2016
OSHA cited a Colorado steelmaker for 10 serious violations after conducting an inspection under the agency’s National Emphasis Program for Amputations. The case involved $103,820 in proposed penalties.

The company was cited for failing to provide standard guardrails on open-sided floors and platforms 4 feet or more above a lower level or provide bumper stops to stop rail cars from potentially rolling in a crosswalk or vehicular traffic, posing a risk of collisions or crushing impacts.

Discount Retailer Cited, Fined $105,600: July 2016
OSHA cited a national discount retailer and issued serious violations for not keeping storage areas free of materials that posed tripping hazards and for not guarding open-sided floors or platforms with toeboards and railings, thus presenting a fall hazard, at a Kansas store. With those and other citations from that store came $17,600 in proposed penalties to the retailer.

"Piling up merchandise and blocking exit routes puts workers—and customers—at risk," said Judy Freeman, OSHA's area director in Wichita.