OSHA 1910.136 – Safety Standards for Foot Protection

“OSHA’s Foot Protection standard is foundational to what we do. For over 100 years, Lehigh has been an innovative supplier of safety footwear. We continuously evolve our program with unique services, product, and technology to give companies the most efficient, cost-effective, trackable, and manageable way to keep their workers protected and productive.” Lehigh CustomFit – 1-800-444- 4086 LehighCustomFit.com

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Tasked as they are with transporting people as they walk, run, climb, squat and do other activities, it should be no surprise that feet are complicated structures that contain approximately 25% of all the bones found in the human body. Those 26 bones – along with 100+ muscles and 33 joints – are at risk from a variety of workplace hazards. Feet may be:

• Crushed by moving vehicles
• Struck by falling objects
• Punctured by sharp objects and loose nails
• Sprained by falls on slippery floors
• Burned by chemicals
• Harmed by extreme temperatures

According to the U.S. Bureau of Labor Statistics[1] tally of nonfatal occupational injuries and illnesses in private industry, there were 93,610 foot injuries and 99,690 ankle injuries involving days away from work from 2021-2022. Traumatic injuries and disorders accounted for 93,300 foot and 98,850 ankle injuries. Some 200 workers suffered foot fractures from 2021-2022, while 370 experienced fractures in their ankles.

Foot injuries can have both short- and long-term consequences. Depending upon the extent of the injury, they can impede an employee’s ability to return to work, require ongoing or future medical treatment and cause permanent disability — in addition to affecting productivity and hampering a company’s ability to maintain appropriate workforce levels.

The Numbers

Citations regarding this standard by Federal OSHA for inspections during the period October 2022 through September 2023:

General Requirements

OSHA[2] mandates 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, 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.

Protective footwear must comply with any of the following consensus standards:

• ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear”
• ANSI Z41-1999, “American National Standard for Personal Protection — Protective Footwear”
• ANSI Z41-1991, “American National Standard for Personal Protection — Protective Footwear”

Protective footwear that the employer demonstrates is at least as effective as protective footwear that is constructed in accordance with one of the above consensus standards will be deemed to be in compliance with the requirements of this section.

As with all forms of personal protective equipment, OSHA requires footwear to be safely designed and constructed and maintained in a clean and reliable fashion. It should fit comfortably, encouraging worker use. If the personal protective equipment does not fit properly, it can make the difference between being safely covered or dangerously exposed. When engineering, work practice and administrative controls are not feasible or do not provide sufficient protection, employers must provide personal protective equipment to their workers and ensure its proper use.

Types of Foot Protection

Choosing the right form of foot protection should start with an assessment of hazards and of the individual needs of the wearer. Workers who may be exposed to crushing injuries will benefit from footwear with steel or composite safety toes and metatarsal guards. Chemical-resistant shoes and slip-on overshoes can protect against a variety of toxic substances. Thermal insulated and waterproof shoes and boots can help combat wet, hot or cold environmental conditions. Slip-resistant shoes can prevent falls on greasy or wet surfaces. Where electric hazards are present, footwear that is static dissipative or non-conductive is a good choice. WMHS

[1] https://www.bls.gov/iif/nonfatal-injuries-and-illnesses-tables.htm

[2] https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.136