OSHA 1910.136(a): Foot Protection
History:
As part of the rules and regulations regarding workplace safety, the Occupational Safety & Health Administration (OSHA) requires protective footwear for workers in industrial settings. Occupational foot protection is included in the Personal Protective Equipment (PPE) section of the Occupational Safety and Health Standards, specifically 29 CFR 1910.136.
The existing OSHA standards for PPE are contained in Subpart I of OSHA’s general industry standards. These standards were adopted in 1971 from established federal standards and national consensus standards. Originally, 29 CFR 1910.136 incorporated the ASTM F2412-05 Standard Test Methods for Foot Protection, F2413-05 Standard Specification for Performance Requirements for Protective Footwear and the American National Standards Institute (ANSI) American National Standard for Personal Protection-Protective Footwear (ANSI Z41-1999 and Z41-1991). In March 2005, the ANSI Z41 reference was withdrawn and replaced by the ASTM Standards.
In 2007, OSHA issued a rule requiring employers to provide PPE at no cost to their employees when the PPE is used to comply with OSHA standards. Specific to footwear, the rule said employers aren’t required to pay for non-specialty, safety-toe protective footwear when the employee is able to wear it off the workplace. But, if employees are required by employers to keep non-specialty safety-toe protective footwear at the workplace, companies must pay for that footwear. If the safety-toe protective footwear is a non-standard “specialty” item, such as nonskid shoes, the employer must pay for them. OSHA also orders employers to pay for required footwear using metatarsal protection.
Why Standard is Important:
According to data from the U.S. Bureau of Labor Statistics, a total of 5,190 workers died from an occupational injury in 2016. This number increased by 7% from 2015 and is the highest count since 2008.
Companies that do not comply with OSHA regulations can find themselves with citations and fines. Fees for violations start at a few thousand dollars, but OSHA raised its maximum penalties in 2018 from $12,600 to $12,934 for “serious” and “other-than-serious” violations. Plus, “willful or repeat” violations can now carry a maximum of $129,336.
BLS data also reports approximately 120,000 workers annually suffer from toe, foot and ankle injuries, which average six days to heal. Adding up the cost of OSHA fines, plus the loss in productivity caused by an injury and possible workers’ compensation costs, as well as the possibility of an additional hire, lack of foot protection can mean big bucks for a company.
Key Compliance Requirements:
OSHA’s 1910.136 (a) standard says: “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 staticdischarge or electric-shock hazard, that remains after the employer takes other necessary protective measures.”
OSHA suggests protective footwear be worn in situations involving the following: corrosive or poisonous materials; electrical hazards; static electricity that could cause an explosion; heavy objects that could roll onto feet; sharp objects that could puncture the foot; molten metal that could splash onto feet; and hot or slippery surfaces.
Employers are responsible to ensure employees wear footwear that protects against the hazards they will encounter on the job. The footwear also must meet industry consensus standards, such as ASTM F2412-11, Standard Test Methods for Foot Protection, which requires footwear’s performance to be evaluated for impact and compression resistance in the toe area; metatarsal and puncture protection; conductive properties to reduce hazards from static electricity buildup; electrical hazards from stepping on a live wire; and static dissipative properties.
OSHA recommends companies conducting an assessment either by an in-house safety staff member or by an outside consultant to determine the correct protective footwear.
Compliance Assistance:
For more information, please visit: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.136
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Following OSHA standards does not only lead to a safer workplace, but also results in greater productivity and profitability for your business. When employees know that they are safe at work, they feel valued by their employer, and that empowers them to be personally invested in their jobs. Impacto Protective Products Inc., 888-232-0031, www.impacto.ca
