Conducting a Footwear Hazard Assessment

Did you know that under the OSHA Personal Protective Equipment (PPE) standard, employers are required to perform a “hazard assessment” of the workplace to identify and control physical and health hazards?  This is to ensure the greatest possible protection for employees in the workplace, which will help in establishing and maintaining a safe and healthful work environment for employees.  

Inclement weather steel toe boots

In a previous blog, I spoke about the footwear requirements for Public Works, so now I would like to dig a little deeper into the actual footwear hazard assessment. 

Many tasks in Public Works involve manual lifting or handling of heavy tools and materials. Foot injuries frequently occur when heavy objects are dropped, resulting in bruises, dislocations, fractures or crushes. Shoes, rubber boots, etc. reinforced with steel toes and/or soles will help prevent foot injuries from impact of falling objects, stepping on sharp objects, or exposure to blades of power tools.

Determining if Foot Protection is Needed or Required

The assessment is an important element of a PPE program because it produces the information needed to select the appropriate PPE for any hazards present or likely to be present at a particular workplace.  Foot protection must be worn when there is a hazard of the following:

• Falling or rolling objects
• Punctures
• Stubbing or banging
• Chemical or corrosive contact
• Electrical shock
• Burns
• Slips and falls

 

Steel toe work boot

What's Involved in Performing a Hazard Assessment?

Since this is a performance-oriented standard, employers must act in a reasonably prudent manner in determining when and how employees, who are exposed to foot injury hazards, are to be protected.  When doing a hazard assessment, you should consider the employee’s task, the likelihood that an employee would be injured without PPE, and the severity of a potential injury. 

After you do a hazard assessment (which can be a simple form or checklist), of course you should document that you have done it!  You can go to the following OSHA link for a checklist version of the PPE assessment, but you can also create your own form. OSHA PPE Check List

Determining Type of Footwear

Once the Public Works hazard assessment is complete, you should select protective footwear based on the assessment. For example:

• Steel-toed shoes/boots to resist impact from any falling or rolling objects
• Sole puncture protection to protect against any sharp or pointed objects that may penetrate the foot
• Metatarsal guards to resist impact that might occur above the toes
• Chemical resistant footwear in areas with potential chemical or corrosive splashes
• Electric shock resistance for work where accidental contact with live electrical conductors can occur

Summary                  

OSHA requires that you implement a PPE program to help you systematically assess the hazards in the workplace and select the appropriate PPE that will protect workers from those hazards.  There is no workplace where a worker is immune to foot injury.  However, the hazards differ according to the workplace and the types of tasks the worker does. The first step in developing a strategy to reduce foot problems is to identify the relevant hazards at the workplace.  Such hazards should be assessed in each workplace, no matter how safe or how dangerous it may seem.

By Jackie Torgerson