Personal Protective Equipment
When a workplace hazard assessment shows that employees may encounter injury to feet and legs, campus management and supervisors should explore all possible engineering and work practice controls to eliminate hazards. If these hazards cannot be eliminated through engineering and work practice controls, supervisors must require that the employees use appropriate personal protection equipment (PPE) to provide additional protection.
Potential hazards include, but are not limited to, falling or rolling objects, punctures (including objects piercing the sole) electrical hazards, chemical hazards, burns (e.g., sparks or molten metal), and environmental and process hazards. See the hazard assessments section on our Personal Protective Equipment (PPE) webpage for information about conducting a hazard assessment.
Protective equipment for the feet and legs commonly includes:
- Safety shoes — Safety shoes have impact-resistant toes and heat-resistant soles. Some shoes have metal insoles to protect against punctures.
- Electrically conductive shoes – These shoes provide protection against the buildup of static electricity.
- Electrical hazard, safety-toe shoes – These shoes are nonconductive and will prevent the wearer’s feet from completing an electrical circuit to the ground.
- Foundry shoes – These shoes have built-in safety toes, insulate the feet from the extreme heat of molten metal, and keep hot metal from lodging in shoe.
- Leggings – This garment protects the lower legs and feet from burn injuries from molten metal or welding sparks.
- Toe guards – Toe guards fit over the toes of regular shoes to protect the toes from impact and compression hazards.
- Metatarsal guards – These guards protect the instep area from impact and compression.
- Combination foot and shin guards – These protect the lower legs and feet.
Areas and personnel affected
Anyone exposed to a workplace hazard that could injure the feet or legs need to be protected from that hazard. Areas and personnel most likely to need foot/leg protection include:
- Certain art studios and workshops staff and students
- Physical plant/facilities staff
- Auxiliaries staff
- Custodial staff
Consider the list of occupations from Appendix B of OSHA’s PPE standard for general industry. Their list for foot protection (item 10, Selection guidelines for foot protection) includes: “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, 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.”
Training and employee information
Employees must get information and training that enable them to be apprised of the hazards present in their work, and to understand the correct use of personal protective equipment. The minimal training requirements to be met are in 29 CFR 1910.132(f). In summary, campuses must train each employee who must use PPE to know and demonstrate the following items prior to using the PPE:
- When PPE is necessary.
- What PPE is necessary.
- How to properly put on (don), take off (doff), adjust and wear the PPE.
- The limitations of the PPE.
Additional training or retraining of employees needs to be done when a previously trained employee is not demonstrating the proper understanding and skill level in the use of PPE, or when there are changes in the workplace or in the type of required PPE that make prior training obsolete.
Regulations, interpretations and standards
In addition to the following regulations, the OSHA regulations state that protective footwear must comply with certain consensus standards (see section on Consensus Standards below).
29 CFR 1910.132 – General requirements – Includes the hazard assessment and training requirements.
29 CFR 1910, Subpart I, Appendix B, – Non-mandatory compliance guidelines for hazard assessment and personal protective equipment selection
OSHA Letters of Interpretation
There are numerous OSHA letters of interpretation concerning personal protective equipment. Go to the OSHA Standards Interpretation page for General Industry and you can search by keyword, or by regulatory section (PPE regulations in Subpart I appear in 1910.132–1910.138).
OSHA Directive CPL 02-01-050. 29 CFR Part 1910, Subpart I, Enforcement Guidance for Personal Protective Equipment in General Industry.
Wisconsin Department of Safety and Professional Services
The Wisconsin Department of Safety and Professional Services (DSPS) adopted OSHA’s Subpart I Personal Protective Equipment (PPE) standards, and other PPE requirements in other specific standards, as the rule for public employees in Wisconsin. No modifications or amendments have been adopted.
The OSHA regulations state that protective footwear must comply with any of the following three consensus standards:
- ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear,” which are incorporated by reference in § 1910.6;
- ANSI Z41-1999, “American National Standard for Personal Protection — Protective Footwear,” which is incorporated by reference in § 1910.6; or
- ANSI Z41-1991, “American National Standard for Personal Protection — Protective Footwear,” which is incorporated by reference in § 1910.6.
Reference material, files, and websites
General reference material
Protective Footwear; UW-Milwaukee (webpage)
Protective Footwear Requirements; Quick Tips Technical Document 252, Grainger Safety
Reference material for this webpage
Personal Protective Equipment. OSHA 3151-12R, 2003
This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.