A good safety footwear program begins not with selecting a new pair of shoes or boots, says Michael Ziskin, CHMM, but by "addressing all of the walking and working surfaces that employees are going to be exposed to and assuring that they are in the best condition possible."
OSHA's personal protective equipment standard, 1910.132 (d)(1), requires that employers "assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment."
Ziskin, president of Field Safety Corp., Guilford, Conn., says that employers should use the risk assessment process to take a broad look at working conditions and procedures, and to examine a range of possible hazard controls.
There is certainly sufficient financial incentive for industry to pay close attention to foot-related hazards. Workers suffered 180,000 disabling injuries to the feet and toes in 1995, according to the National Safety Council. During that same period, says the National Council on Compensation Insurance, injuries to the feet and toes cost an average of $6,700 per claim.
But foot and toe injuries are only part of what can happen with a poor footwear program, says Bill Mills, president and COO of safety shoe manufacturer Iron Age Corp., Pittsburgh. "Have you had slips and falls in the workplace, or lower back fatigue? Are employees tired at the end of the day and less likely to perform effectively? Can that result in other, secondary injuries? The answer to all of those things is certainly "yes"."
What to Look For
In the hazard assessment process, Ziskin says safety and health managers should consider the kinds of operations within a facility, the processes being used, the tasks being performed, environmental conditions and the nature of any chemicals in use. They also have to examine "key human performance factors," he says, such as the fit of footwear or whether the foot will sweat profusely. "Before we select any protective equipment, we have to ask ourselves: Why are we protecting this individual? What are we protecting him from? Why is he walking in there?" he says.
This hazard assessment should consider simultaneous as well as single hazards. "With footwear, you could be walking on a wet surface, but that wet surface can also be chemically contaminated and you could be working with electrical sources," Ziskin says.
OSHA requires that employers document that the hazard assessment has taken place. This written certification includes the identity of the workplace evaluated, the name of the person who performed the evaluation, and date(s) of the hazard assessment. Ziskin's advice to companies that have a successful foot protection program: Start the process by documenting a past history of acceptable performance. Says Ziskin, "If I am an OSHA inspector and I come in and say, "How did you establish this footwear choice?", you say, "Because we"ve been using it for 25 years and we have an extremely low accident and injury rate relative to slips, trips and falls. We have a high degree of compliance, and we don't have any problems." Now, that's pretty good justification." He adds that other documentation might refer to specific standards or test data for specialized footwear, such as that for electrical safety or chemical protection.
In determining how to eliminate or minimize hazards, Ziskin maintains that safety and health pros should adhere to the traditional control hierarchy of engineering controls, administrative procedures and then personal protective equipment, such as footwear.
Preparing walking and working surfaces is a "prerequisite" to selecting footwear, says Ziskin. For example, with a wet surface, he says the employer needs to ask: ""Why is there liquid on the floor?" Let's get rid of it. Let's not accept that workplace condition to be the norm."
Another question is whether employees need to be in an area. If not, then barring them offers an effective remedy for any potential foot-related incidents.
Employers also need to consider changes in the work environment, such as new flooring or process realignment, or in job tasks, and reassess what footwear is needed based on those changes.
Iron Age's Mills says that an assessment of foot-related hazards has the added benefit of being cost-effective. He says hazard assessment helps get a "better handle on utilizing the right products for the environment so that you get (longer wear) and comfort for the employee wearing" the shoes or boots.
Ziskin warns against "regulatory tunnel vision," in which foot protection choices are based strictly on compliance with OSHA standards. He noted that workers' compensation claims and potential legal liability, which are both more expensive than OSHA citations, should also be assessed.
"What drives our decisions to develop and implement a program?" he asks. "What are the criteria by which we want to judge that program as being effective? Is it limited to OSHA compliance, or is it going to be based on a reduction in claims or on a consensus within the organization and with legal counsel that this is a risk reduction strategy that will offset exposure to litigation by demonstrating good faith and a very proactive approach by management?"
Choosing the Right Footwear
OSHA's foot protection standard, 1910.136(a), requires protective footwear to be used when employees are "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."
Protective footwear must comply with American National Standards Institute standard ANSI Z41-1991, which breaks footwear down into six categories:
- Impact- and compression- resistance, which uses a steel or nonmetallic toe cap (steel toe) to protect against falling objects or crushing from heavy rolling objects.
- Metatarsal footwear, which provides similar protection against falling objects to the area of the foot between the ankle and the toes.
- Electrical hazard, where the sole of the shoe or boot is designed to protect workers from electric shock from 600 volts or less, under dry conditions.
- Conductive footwear, which prevents the buildup of static electricity.
- Puncture-resistance, where the sole resists penetration from sharp objects; such as nails or broken glass.
- Static-dissipative, which reduces the buildup of static electricity by conducting body charge to ground, while protecting the employee from electrical hazards.
Slips and falls are a major concern at many workplaces. John Cockrell, Ph.D., the owner of SKL Laboratories, Greensboro, N.C., notes that employers often simply tell workers to choose "slip-resistant shoes," but in fact, the majority of shoes are "not slip-resistant at all, even though some claim to be." Cockrell, who tests shoes and flooring materials for slip-resistance for about 50 major corporations, says that safety and health staffs trying to sort through manufacturers' claims should get referrals from other firms, ask manufacturers for references, or send footwear to a laboratory for testing.
When you walk, explains Cockrell, "Your foot is pushing forward and down, and friction is pushing backward and up. Friction has to be greater than the force your foot is creating in order to keep your foot from continuing in a slip." Using test methods outlined in ASTM F16-77, Cockrell says, a .25 slip-resistance is needed to prevent the average person from slipping, where "the .25 is the ratio of the horizontal to vertical force" created by the person's step.
A common mistake concerning footwear is to equate the rugged grip of a hiking-style boot with slip-resistance, says Cockrell, who serves as a consultant to slip-resistant shoe manufacturer Shoes for Crews, based in West Palm Beach, Fla. While such deep-tread boots are marketed as having great traction, he explains, "most of those kinds of boots are exceedingly slippery on a smooth floor with a slippery foreign substance on it."
Similarly, Cockrell says, many workers in food service believe athletic shoes that have a good grip on a clean, dry basketball court will be slip-resistant in the workplace. But, he notes, these shoes have a rubber sole that is hard, designed for long wear. On a floor covered with a foreign substance, they offer little slip-resistance.
"All rubber is not created equal," says Cockrell. "It is exceedingly difficult to formulate slip-resistant rubber.
OSHA's PPE standard requires employers to "select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment."
In addition, the OSHA standard requires employers to train employees on how to use, maintain and dispose of their safety footwear.
Safety footwear experts say that almost as important as choosing the proper footwear is knowing when to replace it. John Klein, marketing manager for Red Wing Shoes, Red Wing, Minn., a manufacturer of industrial footwear since 1905, favors replacing shoes on an as-needed basis, rather than on a calendar cycle. "You have to do the appropriate, timely inspection. Is the sole worn out? Is the leather upper intact? You have to clean the soles periodically so the shoe can maintain its ability to grip and have traction. Clean out the tread and get rid of contaminants."
For slip-resistant footwear, says Cockrell, "You need to replace the shoe when the tread pattern is gone from the rear two-thirds of the heel. That's the critical part of the shoe."
The service life of safety footwear will depend on the working environment. "An employee who works in a steel mill or on a pot room line in the aluminum industry, for instance, will go through more shoes in the course of a year than someone in a warehousing application," says Mills, "but they all need to be cognizant of when that shoe has reached its full life extent, then purchase another pair of shoes so that they protect the employee."
Employers greatly affect the replacement of shoes by how they structure their shoe subsidy program. "Where you have a company that is providing an adequate subsidy and offering payroll deduction for employees," says Mills, "you generally see strong programs with limited injuries in the workplace."
Finding a Comfortable Fit
There is little doubt that workers will have a tough time keeping smiles on their faces if they are suffering from sore, aching feet caused by uncomfortable or poorly fitting footwear.
A common misconception is that safety shoes with steel toes are uncomfortable, but Jim Falcinelli, director of marketing for Hy-Test Boots and Shoes, a division of Wolverine Footwear Group, points out that the steel toe is completely surrounded by padding. "If the steel-toe (shoe) is properly fitted, you can't tell it's there," he says.
Falcinelli also notes that, while steel toes are considered "too heavy," they weigh only about 2 ounces. "What makes a safety shoe weigh more is the padding, cushions, and durability (the density of the outsole) which protects against oils, chemicals and abrasion, which the hazard dictates," he explains.
Iron Age's Mills says that proper fitting of steel-toe shoes is particularly important. "That steel cap is not going to go anywhere," he says, noting that if the shoe is too short or narrow, the cap may feel only a little snug at first. "It's just a matter of time in wearing the shoe before it becomes very uncomfortable."
Don Johnson, director of sales, duty and occupational footwear, Rocky Shoes and Boots, Nelsonville, Ohio, offers these fitting tips:
- Measure both feet. "It's very important that the person measures both the left and right foot," says Johnson. "Most people are right-handed, and, usually, their right foot is a little bigger." To get the best sizing information, measure from the toe to the heel, the ball of the foot to the heel, then the width. Try both shoes on and walk around in them, if possible.
- Try shoes on in the afternoon. "When you've been on your feet all day, they swell and expand," notes Johnson. If you have sensitive areas on your feet and they hurt when trying a shoe on at that time of day, he said, then you know you need to try a different style.
- Wear a normal work sock. If you wear a thicker or thinner sock at the time of selection, it could result in the choice of shoe that is too small or too big.
- Rotate between old and new shoes. Don't wait until your shoes are totally worn out before you get a new pair. "When you get to three months, go get another pair and then start rotating them. Both pairs will last longer and be more comfortable," says Johnson.
"Footwear to an awful lot of people is not the most glamorous aspect of their job," one safety footwear expert admitted. But, glamorous or not, foot-related injuries remain widespread and costly, and close attention to a safety footwear program can offer a generous return in improved safety and productivity.