1910 136 Foot Protection

By Steve Stephenson

According to the Bureau of Labor Statistics, most of the workers in selected occupations who suffered impact injuries to the feet were not wearing protective footwear. Furthermore, most of the employers did not require their workers to wear safety shoes. The typical foot injury was caused by objects falling less than four feet and the average weight of the object was about 65 lb. Most workers were injured while performing their normal job activities at their work-sites.

The OSHA Requirements Are:

1910.136(a) - General requirements. 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.

OSHA 1910.136 is a short, simple standard. It opens with the above statement requiring foot protection, and then sets the criteria for foot protection as being footwear that complies with any of the following:

ASTM F-2412-11, "Standard Test Methods for Foot Protection," and ASTM F-2413-11, "Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear," or
ANSI Z41-1999, "American National Standard for Personal Protection -- Protective Footwear," or
Any other footwear that has been demonstrated to be at least as effective as footwear made in compliance with one of the above.

When Must Foot Protection be Worn?

It is the employer's responsibility to determine which of their employees, if any, are exposed to a foot injury hazard. To accomplish this employers are required to contact a hazard assessment to identify potential health and physical hazards. Examples of physical hazards that may injure feet include areas where:

there may be heavy, rolling objects (barrels, pipes, or tools);
there are objects that may fall;
sharp objects may pierce the sole of a shoe (nails, spikes, or sharp scrap metal);
there may be hazardous chemicals that can slash onto feet or the floor;
there are slippery surfaces;
there may be exposure to high temperatures (such as molten metal);
there is exposure to electrical hazards. If there is the possibility an employee’s feet may be exposed to electrical hazards, then non-conductive footwear should be worn. But, if there is the possibility of exposure to static electricity, then wearing conductive footwear is appropriate.

What to do about Foot Hazards

When foot injury hazards are identified the first option is to eliminate them by redesigning equipment, the process, or the facility. If the hazards cannot be eliminated, they should be guarded to prevent access. If they cannot be guarded, administrative rules or procedures can be used to minimize exposure to the hazard. The last line of defense is foot protection.

Identifying a foot injury hazard does not mean that employees exposed to the hazard are required to wear foot protection at all times. Foot protection must only be worn while an employee is exposed to the hazard. If there are times when the employee is not exposed to the hazard, OSHA does not require foot protection. Whether foot protection is to be worn when not required by OSHA is a matter of employment conditions established by the employer or by a union contract.

OSHA 1910 Subpart I Appendix B identifies some occupations for which foot protection should be routinely used. OSHA notes that this is not a complete list:

shipping and receiving clerks
stock clerks
carpenters
electricians
machinists
mechanics and repairers
plumbers and pipe fitters
structural metal workers
assemblers
drywall installers and lathers
packers, wrappers, and craters
punch and stamping press operators
sawyers
welders
laborers
freight handlers
gardeners and grounds-keepers
timber cutting and logging workers
stock handlers
warehouse laborers

What Type of Foot Protection is Needed?

Different footwear protects in different ways. Check the product’s labeling, or consults the manufacturer, to make sure the footwear will protect the user from the hazards they face. Foot and leg protection choices include the following:

Leggings are used to protect the lower legs and feet. They are used in situations such when there are welding sparks or the potential for splashes from molten metal. Leggings are typically equipped with safety snaps that allow them to be quickly removed.
Metatarsal guards are strapped onto the outside of shoes to protect the instep area from impact and compression.
Toe guards fit over the toes of regular shoes. They protect the toes from impact and compression hazards.
Safety shoes have impact-resistant toes and heat-resistant soles. Some safety shoes include metal insoles to protect against punctures. When workers are in areas with potentially explosive atmospheres, safety shoes may be electrically conductive to prevent the buildup of static electricity. In areas where there is exposure to electrical power, safety shoes will be non-conductive, providing protection against electrical shock and burns.
Special purpose safety shoes - there are a variety of safety shoes designed for specific industries. Here are two examples:
- Cork boots, sometimes called “caulk boots” are used in logging. The soles of corks are covered with small spikes that provide traction when walking on logs.
- Foundry shoes provide insulation against the extreme heat of molten metal. In addition, foundry shoes are designed to keep hot metal from lodging in shoe eyelets, tongues or other shoe parts. They are snug-fitting leather shoes that have leather or rubber soles, rubber heels, and built-in safety toes.

Care of Protective Footwear

While OSHA 1910.136 does not include specific care requirements, if safety footwear does not receive proper care, it will deteriorate and will no longer provide the necessary protection.

As with all PPE, safety footwear should be regularly inspected. If safety shoes are used every day, they should be inspected every day before putting them on. Check for damage, excessive wear, and any tears or cracks. Look for punctures, holes, gouges, separation of materials, and broken buckles. If the laces are broken or worn, replace them.

Look at the soles of each shoe to see if there are pieces of metal or other materials embedded in the sole. Check for anything on the shoe that might cause electrical or tripping hazards.

Finally, at the end of each day follow the manufacturers' recommendations for cleaning and maintenance of your safety shoes.