1910 136 Foot Protection

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?

  Protection Type	Protects Against	Common Use
  Leggings	Sparks, molten metal splashes	Welding and foundry work
  Metatarsal Guards	Instep impact and compression	Heavy material handling
  Toe Guards	Toe impact and compression	Temporary hazard exposure
  Safety Shoes (Impact Toe)	Falling or rolling objects	General industrial environments
  Puncture-Resistant Shoes	Nails, sharp scrap, spikes	Construction and demolition
  Electrical Hazard (EH) Shoes	Electrical shock exposure	Electrical work areas
  Conductive Shoes	Static electricity buildup	Explosive atmospheres
  Specialty Boots (e.g., Cork, Foundry)	Slippery logs, molten metal	Logging, foundries

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