Safety Tidbit #2.14 - Steel-toed shoes Yes or No?

Safety Tidbit #2.14 – Steel-toed shoes Yes or No?

Source:            OSHA 29CFR1910.136 Foot Protection

                        OSHA 29CFR1910.132 Personal Protective Equipment

The Bureau of Labor Statistics reported 5% of all recordable injuries were related to the feet and I am sure all of you fielded the question: “Does OSHA require steel-toed shoes for my workplace?” And the answer being “yes” and “no.”  However, to really answer the question, we need to take a step back. OSHA requires the employer to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). [1910.132(d)(1)] Furthermore, the employer must certify, in writing, that the assessment has been performed and note the date and the workplace evaluated. [1910.132(d)(2)] Meaning the employer followed a systematic procedure which includes intentional thinking about the hazard and how to minimize its effect on the worker.  In this case through the use of the last line of defense or personal protective equipment.  Note: I’m not going to discuss actually reducing or getting rid of the hazard using any one of the other control measures in the Hierarchy of Control toolbox.

So back to the client’s question: Does OSHA require steel-toes shoes in my workplace?  Well there are approximately 18.2 million businesses in the United States.  So OSHA won’t actually say if steel-toed shoes are required in your particular workplace also they don’t prescribe personal protective equipment necessary based on type of workplace again because of potential variability. However, they do say that when working in areas where there is a danger of foot injuries or rolling objects, or objects piercing the sole the employer shall ensure that each affected employee uses protective footwear [1910.136(a)].

So when you assessed the workplace and the operations performed in the workplace and you identified the potential for your employees to injure their feet, your answer is “yes” and you need to require some sort of protective footwear.  Furthermore, if, upon closer inspection, you identified that the danger to your employees’ feet involved crushing possibly by a rollover or from dropping items on their feet then you need to require steel-toed shoes. Actually, more correctly you need to require shoes meeting the American National Standards Institute (ANSI) American National Standard for Personal Protection—Protective Footwear ANSI Z41-1999 and ASTM F2413-05 Standard Specification for Performance Requirements for Protective Footwear.

Last note, make sure you check your employees’ shoes periodically to ensure they are in good repair and will work in accordance with the ANSI and ASTM specifications as designed by the manufacturer.  You are responsible to train your employees on proper use and care of their personal protective equipment.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan