Protective Footwear Requirements
Protective footwear requirements are referenced in the Department of Labor’s Code of Federal Regulations (CFR) Title 29. General PPE requirements are given in the Occupational Safety and Health Administration’s (OSHA’s) standard 1910.132 and Foot Protection requirements are in 1910.136.
According to 29 CFR 1910.132, PPE must be used whenever an employer’s workplace hazard assessment determines that hazards that require PPE are present, or are likely to be present.
Per 29 CFR 1910.136(a), “Each affected employee shall wear 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.” Appendix B to Subpart I identifies the following occupations for which foot protection should be routinely considered: “shipping and receiving clerks, stock clerks, carpenters, electricians, machinists, mechanics and repairers, plumbers, assemblers, drywall installers and lathers, packers, wrappers, craters, punch and stamping press operators, sawyers, welders, laborers, freight handlers, gardeners and grounds keepers, timber cutting and logging workers, stock handlers and warehouse laborers.”
29 CFR 1910.136 incorporates by reference 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).
On March 1, 2005, the ANSI Z41 reference was withdrawn and replaced by the ASTM Standards.
On September 9, 2009, OSHA issued an update to its PPE standards. The final rule went into effect in October 2009. This final rule revised the PPE sections of OSHA’s general industry, shipyard employment, longshoring and marine terminals standards regarding requirements for eye and face protective devices, and head and foot protection.
The revision updated the references in these regulations to recognize the three most recent editions of the applicable national consensus standards and allows employers to use PPE constructed in accordance with any of the three.
ASTM F2412-11 (Standard Test Methods for Foot Protection) and ASTM F 2413-11 (Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear are the most current footwear consensus standards. This document provides an overview of ASTM F2413-11.
ASTM F2413-11 Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear covers minimum requirements for the design, performance, testing and classification of protective footwear. The purpose of this standard is the certification of protective footwear. The certification must be performed by independent third party laboratories.
Footwear certified as meeting ASTM F2413-11 must first meet the requirements of Section 5.1 Impact Resistant Footwear and Section 5.2 Compression Resistant Footwear. Then the requirements of additional sections such as metatarsal protection, conductive protection, electric hazard resistance, static dissipative protection and protection against punctures can be met.
All footwear manufactured to the ASTM specification must be marked with the specific portion of the standard with which it complies. One shoe of each pair must be clearly and legibly marked (stitched in, stamped on, pressure sensitive label, etc.) on either the surface of the tongue, gusset, shaft or quarter lining. The marking must be enclosed in a rectangular border and a four-line format is suggested. Line four is used only when more than three sections of the standard applies to the footwear.
Each protective toe cap must be marked with the manufacturer’s name, trademark or logo. The cap number or identification, toe cap size and R (right) / L (left) must be permanently stamped or marked in a conspicuous location. Each metatarsal and puncture-resistant device must be marked with the manufacturer’s name, trademark or logo and device number or identification in a conspicuous location.
The following is an example of an ASTM F2413-11 marking that may be found on protective footwear:
This line identifies the ASTM standard. It indicates that the protective footwear meets the performance requirements of ASTM F2413 issued in 2011.
This line identifies the gender (M [Male] or F [Female]) of the user. It also identifies the existence of impact resistance (I), the impact resistance rating (75 foot-pounds), compression resistance (C) and the compression resistance rating (75) which correlates to 2500 pounds of compression. The metatarsal designation (Mt) and rating (75 foot-pounds) is also identified.
Lines 3 and 4 are used to identify footwear made to offer protection from other specific types of hazards referenced in the standard. They are used to designate conductive (Cd) properties, electrical hazard resistance properties (EH), footwear designed to reduce the accumulation of excess static electricity (SD) and puncture resistance (PR).
Conductive (Cd) footwear is intended to provide protection for the wearer against hazards that may result from static electricity buildup and to help reduce the possibility of ignition of explosives or volatile chemicals. The footwear must facilitate electrical conductivity and the transfer of static electricity buildup from the body to the ground. The electrical resistance must range between zero and 500,000 ohms.
Electrical hazard (EH) footwear is manufactured with non-conductive, electrical shock-resistant soles and heels. The outsole is intended to provide a secondary source of electric shock-resistance protection to the wearer against the hazards from an incidental contact with live electrical circuits, electrically energized conductors, parts or apparatus. It must be capable of withstanding the application of 18,000 volts at 60 hertz for one minute with no current flow or leakage current in excess of one milliampere under dry conditions.
Static dissipative (SD) footwear is designed to provide protection against hazards that may exist due to excessively low footwear resistance, as well as maintain a sufficiently high level of resistance to reduce the possibility of electric shock. The footwear must have a lower limit of electrical resistance of 106 ohms and an upper limit of 108 ohms.
Puncture-resistant (PR) footwear is designed so that a puncture-resistant plate is positioned between the insole and outsole. It is an integral and permanent part of the footwear. Devices constructed of metal must pass the ASTM B117-11 Standard Practice for Operating Salt Spray (Fog Apparatus) corrosion resistance testing. The device must show no sign of corrosion after being exposed to a five percent salt solution for 24 hours. The puncture-resistant footwear must show no signs of cracking after being subjected to 1.5 million flexes and have a minimum puncture resistance of 270 pounds.
Any changes to the original components of safety toe footwear such as replacing or adding aftermarket footbeds/inserts could cause failure to any or all parts of the ASTM standard and the marking would be invalid.
An important point to remember is that the ASTM standard does not allow for the use of add-on type devices (strap-on foot, toe or metatarsal guards) as a substitute for protective footwear. According to the ASTM standard, any protective toe cap or metatarsal guard must be designed, constructed and manufactured into the protective footwear during the manufacturing process and tested as an integral part of the footwear.
While ASTM excludes add-on devices, it doesn’t necessarily mean they’re not acceptable to OSHA. This paradox exists because OSHA states in 1910.136(b)(2) “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.” This means that if an employer can provide documentation, such as testing data proving their add-on devices provide protection equivalent to any of the incorporated by reference performance standards, then the add-on devices are acceptable to OSHA. Most manufacturers of add-on devices have submitted their products to independent laboratories for testing. This data and its results can be obtained upon request.
OSHA 29 CFR 1910.132 -
Personal Protective Equipment General Requirements
OSHA 29 CFR 1910.136 -
Personal Protective Equipment Occupational Foot Protection
ASTM B117 -
Standard Practice for Operating Salt Spray (Fog) Apparatus
ASTM F2412-05 -
Standard Test Methods for Foot Protection
ASTM F2413-05 -
Standard Specification for Performance Requirements for Foot Protection
ASTM F2412-11 -
Standard Test Methods for Foot Protection
ASTM F2413-11 -
Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear
Rev. Date: 6/2015
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