Page 32 - Occupational Health & Safety, January 2018

FOOT PROTECTION
Foot Protection Essentials
The OSHA 1910.136 standard and the ASTM F2412-11 standard indicate how many kinds of foot injury are possible, some of them even disabling.
BY JERRY LAWS
Adocument listing severe work-related inju- ries reported to OSHA from Jan. 1, 2015, through March 31, 2017, is available on- line, and it makes sobering reading. Am- putations, slips and falls, crushing injuries, and many more types of serious incidents from federal OSHA states are listed there. Slips and foot injuries are com- mon, such as this one from January 2015 in St. Louis:
“An employee was setting a string of four railcars in the yard with his groundsman. The groundsman secured the ground hand brake on the first railcar and unhooked the string from the railcar. The employee noticed a railcar starting to move as the manual ground brake on the first railcar failed. He attempted to set the brake on the second car when the railcar wheel smashed his steel toe boot to the ground, frac- turing his right foot and removing a toenail.”
That’s a short description of severe trauma, I’m sure you’ll agree, even though this worker was wear- ing protective footwear to shield him against crushing impacts. The database1 doesn’t say anything about the medical costs of all of those injuries, enforcement ac- tion taken, the amount of time lost, or whether the injured employee ever returned to work.
A good starting point for what employers need to do is to read 29 CFR 1910.136, Foot protection, OSHA’s general industry standard. At 1910.136(a), it says this:
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 pierc- ing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protec- tive measures.
Workers in many industries require footwear that offers protection against the hazards mentioned in that section of the standard, especially against impact, and also slip resistance.
Employer Responsibilities
It’s the responsibility of employers, and by extension their safety and procurement managers, to ensure employees wear footwear that protects against the hazards they will encounter on the job, and that the footwear meets the important industry consensus standards, such as ASTM F2412-11, Standard Test Methods for Foot Protection—its test methods con- tain requirements to evaluate footwear’s performance
for impact and compression resistance in the toe area, metatarsal protection, puncture protection, conduc- tive properties to reduce hazards from static elec- tricity buildup, electrical hazards from stepping on a live wire, and static dissipative properties. Another employer responsibility is to ensure the footwear is maintained properly and replaced when necessary.
The OSHA standard and the ASTM F2412-11 standard indicate how many kinds of foot injury are possible, some of them even disabling. “The most common sprains are to the ankle,” Ron Bowles, di- rector of operations for MoveSMART, a system for preventing strains and sprains, slips and falls, and hand injuries, said during his Nov. 30, 2017, OH&S Academy webinar, “Making the Right Moves to Pre- vent Strains and Sprains.” He explained why workers experience sprains and strains, that soft-tissue injuries account for 33 percent of all lost-time injuries and ill- nesses, and in some workplaces they account for half of them, he said. Bowles outlined ways to assist work- ers in preventing these ailments and discussed bal- ance, force transfer, bracing, and set-up/positioning for doing tasks in his presentation that day.
Benefits of the ‘Employer Pays’ Rule
In November 2007, when OSHA issued a final rule saying employers must provide PPE at no cost to their employees when that PPE is used to comply with OSHA standards, then-Assistant Secretary Edwin Foulke said the agency estimated the rule would pre- vent more than 21,000 workplace injuries annually— such as foot, head, and eye injuries. He explained the rule’s impact this way: When employees pay for their own PPE, they are likely to buy the wrong protective equipment, may use it beyond its expected service life, or may avoid buying it at all. When employers pay for it, however, they are more likely to select the right PPE for the hazards encountered in their workplaces, he said. “When employers pay for PPE, we have found that they also make sure that the equipment is main- tained and replaced as necessary, and generally take more responsibility for PPE selection and use. It is this improvement in PPE usage that is expected to result in fewer injuries and fatalities.”
Jerry Laws is the editor of Occupational Health & Safety.
REFERENCES
1. https://www.osha.gov/severeinjury/xml/severeinjury.csv
26 Occupational Health & Safety | JANUARY 2018
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