Archive Notice - OSHA Archive

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OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

29 CFR 1910.132(a)

March 31, 1976



Regional Administrator/OSHA
SUBJECT: Request for Interpretation-Roadway Express Inc. 29 CFR 1910.132(a) Protective Equipment


This is in response to Mr. Ed J. Largent's letter dated March 23, 1976, which requests clarification on the use of "Sankey Toe Caps", in lieu of safety shoes.

A review of the OSHA standards 29 CFR 1910.132(a) and 29 CFR 1910.136 has been made. If safety shoes are provided, they must meet the requirement as indicated in 29 CFR 1910.136, which is ANSI Z41.1-1967.

If "Sankey Toe Caps" are provided in lieu of safety shoes, the employer has met the intent of the standard and is providing foot protection. As indicated in 29 CFR 1910.132(a) personal protective equipment shall be provided, used, and maintained. The standard does not require specific use of safety shoes as foot protections.

It is suggested, however, that every effort be made to encourage both the employer and the employee to develop a safety shoe program which requires safety shoes as they provide a more reliable protection.

Barry J. White
Associate Assistant Secretary
for Regional Programs